INCOME TAX – deductibility of interest incurred on loans made to two interest in possession settlements in the Isle of Man in circumstances where the proceeds of the loans were ultimately used in the course of a trade carried on by a partnership between the two settlements – consideration of the facts involved in the transaction and whether or not, in the light of those facts, the interest was deductible in computing the quantum of the trading profits of the partnership which were subject to income tax in the hands of the settlors of the settlements – conclusion that the interest was not so deductible – however, as agreed between the parties, an adjustment to the quantum of the trading profits of the partnership for work in progress would be allowed – subject to that adjustment, appeals dismissed
Citations:
[2020] UKFTT 295 (TC)
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 06 February 2022; Ref: scu.653147