The Commissioners for HM Revenue and Customs v Smith and Nephew Overseas Ltd and Others: [2018] UKUT 0393 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Fancourt and Judge Thomas Scott on 29 November 2018.
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CORPORATION TAX 鈥� change in functional currency following reorganisation 鈥� whether relevant accounts complied with UK generally accepted accounting practice 鈥� yes 鈥� whether 鈥渆xchange losses鈥� arose 鈥� yes 鈥� whether exchange differences fairly represented losses arising to the company under Finance Act 1996, s.84(1) 鈥� yes 鈥� appeal dismissed.
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Published 29 November 2018