Chancery Division.

[The appeal against this decision is reported at [1988] BTC 390.]

Judgment delivered 8 April 1987.

Corporation Tax – Losses – Exchange losses on repayment of foreign loans – Loans for five year term – Whether loans on capital or revenue account – Whether losses deductible in computing corporation tax liability.

  This was an appeal by the Crown from a decision of Special Commissioners that exchange losses incurred on the repayment of loans from Swiss banks as a result of the depreciation of sterling, were deductible in computing the taxpayer company’s liability to corporation tax.

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