Chancery Division.

[The appeal against this decision is reported at [1996] BTC 399.]

Sir John Vinelott.

Judgment delivered 25 November, 9 December 1994.

Corporation tax – Chargeable gains – Forward contract to purchase dollars to protect against loss on dollar borrowings if sterling depreciated – Company assessed to tax on currency gain on forward contract – Gain cancelled by non-allowable loss on repayment of loan – Whether forward contract and dollar borrowing linked by binding agreement that forward contract would not be used except for repayment of loan.

Costs – Whether court had jurisdiction to award costs of hearing before the special commissioners.

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