Chancery Division.

[The appeal against this decision is reported at [1991] BTC 150.]

Vinelott J.

Judgment delivered 15 December 1989.

Corporation tax – Capital or income payment – Injection of £50m into insolvent banking subsidiary as a condition of purchase of subsidiary by Bank of England – Stated reason for transaction to preserve taxpayer’s own trade – Whether £50m deductible in computing taxpayer’s profits.

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