Income Tax/Corporation Tax : Anti-Avoidance – Corporation tax – tax avoidance scheme – use of total return swap over shares in subsidiary company to create a deemed creditor loan relationship – value of shares depressed by novating liability for large loans to subsidiary – creating large fair value loan relationship debit in parent company – whether loan relationship had unallowable purpose – subsidiary incurred interest charges on novated loans – whether interest charges also disallowed as loan relationship debits having unallowable purposes – appeal dismissed
References: [2015] UKFTT 582 (TC)
Links: Bailii
Jurisdiction: England and Wales
Last Update: 15 October 2020; Ref: scu.556204
