HBOS Treasury Services Plc v Revenue and Customs: FTTTx 12 Oct 2009

FTTTx Corporation Tax – Joint referral of four disputed issues in relation to treatment of derivatives and to capital gains treatment of the sale of a company – scheme for the avoidance of income recognition on a re-couponing of an ‘in the money’ fixed/floating swap – paras 15 and 28 of Schedule 26 to FA 2002 – capital gains value shifting – Section 30 TCGAct 1992- one issue determined in favour of the taxpayer company and three issues determined in favour of HMRC.

Nowlan TJ
[2009] UKFTT 261 (TC), [2009] STI 3105, [2010] SFTD 134
England and Wales

Corporation Tax, Income Tax

Updated: 01 November 2021; Ref: scu.409075