FTTTx CORPORATION TAX – loan relationships – debit under paragraph 19A, Schedule 9, Finance Act 1996 in respect of the difference in the accounting value of loan relationships on a change of accounting practice – appellant company changing accounting practice from UK GAAP to IFRS at the 2004 year-end – appellant claiming the debit in the 2005 accounting period – whether there was as a matter of fact the relevant difference in the accounting value – expert evidence as to UK GAAP and IFRS considered – found that there was the relevant difference in accounting value – whether in that case the debit was not to be brought into account, as being attributable to an unallowable purpose, under paragraph 13, Schedule 9, Finance Act 1996 – found that the appellant’s tax avoidance purpose was achieved at the 2004 year-end – there were no times during the 2005 accounting period during which the appellant had an unallowable purpose such that on a just and reasonable apportionment any part of the debit was to be attributed to it – appeal allowed
Citations:
[2013] UKFTT 212 (TC)
Links:
Statutes:
Jurisdiction:
England and Wales
Cited by:
Appeal From – Fidex Limited v Revenue and Customs UTTC 13-Nov-2014
Procedure – appeal against closure notice – reliance on grounds for amendment not stated in closure notice – Tower McCashback considered Corporation tax – loan relationships – application of paragraph 13 Sch9 FA 1996 to debit arising under para19A . .
At FTTX – Fidex Ltd v HM Revenue and Customs CA 21-Apr-2016
‘This appeal is concerned with a tax avoidance scheme called Project Zephyr. The object of this scheme was to create a loss of around 84 million Euros in the hands of the appellant (‘Fidex’) which would be available for group relief throughout the . .
Lists of cited by and citing cases may be incomplete.
Corporation Tax
Updated: 17 November 2022; Ref: scu.472799