Overseas Containers (Finance) Ltd. v Stoker (H.M. Inspector of Taxes).  BTC 153
Court of Appeal.
Sir Nicolas Browne-Wilkinson V.-C., Parker and Russell L.JJ.
Judgment delivered 16 March 1989.
Corporation tax – Loss relief – Exchange loss on repayment of foreign loans – Deutschmarks borrowed at a low rate of interest and lent on to parent company at higher rate – Risk of group losses assumed by finance company – Whether loans were trading transactions.
This was an appeal from a judgment of Vinelott J. ( BTC 415) dismissing an appeal from the determination of a Special Commissioner that the taxpayer company (‘OCFL’) was not a trading company whose losses might be set off against the profits of its parent company.