SCIT QUALIFYING CONTRACTS – Profits and losses – Front end payments under currency contracts – Whether qualifying payments – No – Whether to be allocated such that payments are included as ‘amounts B’ – No – Whether currency contracts were entered into for unallowable purposes – Yes – Appeal dismissed – FA 1994 ss 151, 155 and 168A.
Citations:
[2007] UKSPC SPC00636
Links:
Statutes:
Jurisdiction:
England and Wales
Corporation Tax
Updated: 12 July 2022; Ref: scu.262395