CORPORATION TAX – loan relationships – unallowable purpose test – intra-group reorganisation enabled acceleration of use of non-trading loan relationship deficit – Appellants agreed to increase rate of interest on loans – whether Appellants were party to loan relationships for an unallowable purpose – held yes – consideration of amount of debit attributable to that unallowable purpose on a just and reasonable basis – appeal allowed in part
[2021] UKFTT 283 (TC)
Bailii
England and Wales
Updated: 13 October 2021; Ref: scu.667914
