JTI Acquisition Company (2011) Limited Revenue and Customs: FTTTx 19 Apr 2022

Corporation Tax – sections 441 and 442 CTA 2009 – whether non-trade loan relationship debits to be disallowed – UK company incorporated to be the holding company to acquire a US group by stock purchase – cross-jurisdiction intercompany loan between US parent and UK holding – whether the loan relationship had an ‘unallowable purpose’ – whether securing a ‘tax advantage’ was not the main or one of the main purposes – whether attribution on a just and reasonable basis – appeal dismissed


[2022] UKFTT 166 (TC)




England and Wales

Corporation Tax

Updated: 05 July 2022; Ref: scu.678619