Spritebeam Ltd and Others v Revenue and Customs and Others: UTTC 25 Feb 2015

UTTC CORPORATION TAX – company lends money to another group company on terms that shares are paid to a different group company – is the value of the shares income of the lender under the loan relationship rules? – no, but only because of the effect of s. 80(5) of the Finance Act 1996 – is the value of the shares income of the share recipient? – yes – appeals dismissed.

[2015] UKUT 75 (TCC)
Bailii
England and Wales

Corporation Tax

Updated: 01 January 2022; Ref: scu.549071