FTTTx Income Tax/Corporation Tax : Profits – Corporation tax – loan relationships- transfer of contingent debt asset – no profit recognised in accounts – s 84 Finance Act 1996 – ‘fairly represents’ profits – whether accepted accounting method – impact of override in s 84 – held – taxpayer’s accounts GAAP compliant – no alternative set of GAAP compliant accounts – FRS 5 substance approach does not produce fair representation of profits- s 84 override applied – appeal dismissed.
[2015] UKFTT 413 (TC)
Bailii
England and Wales
Corporation Tax
Updated: 03 January 2022; Ref: scu.551538
