Kwik - Fit Group Limited, Stapleton's (Tyre Services) Limited and Others v The Commissioners for HM Revenue and Customs [2022] UKUT 00314 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Swami Raghavan and Judge Rupert Jones on 25 November 2022
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CORPORATION TAX 鈥� loan relationships- unallowable purpose test 鈥� intra-group restructuring of debt 鈥� whether FTT erred in holding utilisation of 鈥渢rapped鈥� losses (Non-Trade Relationship Deficits) in intermediate holding company was 鈥渢ax advantage鈥� 鈥� no - whether FTT erred in finding tax avoidance purpose 鈥� no 鈥� FTT鈥檚 attribution of debits to unallowable purpose upheld 鈥� appellants鈥� and HMRC鈥檚 appeal dismissed 鈥� FTT Decision upheld
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Published 29 November 2022