Stone & Temple Ltd v Waters (HM Inspector of Taxes) and related appeal.  BTC 465
Sir John Vinelott.
Judgment delivered 16 November 1994.
Corporation tax – Trade – Company borrowed funds from parent company which it lent on to a Canadian company, a member of the group, for development of a restaurant and to an individual who took over the running of the restaurant – Whether loans made in the course of trade.
This was an appeal by two companies from a decision of the general commissioners for Croydon that a company which simply advanced sums by way of loan to a fellow subsidiary, and later to an individual, to set up and run a restaurant was not trading.
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