Whittles (HM Inspector of Taxes) v Uniholdings Ltd (No. 3).  BTC 399
Court of Appeal (Civil Division).
Nourse, and Aldous L JJ and Sir John Balcombe.
Judgment delivered 14 May 1996.
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 – Whether Ramsay principle applied, so that gain was cancelled by non-allowable loss on repayment of loan – Capital Gains Tax Act 1979, s. 19(1)(a), 27(1), 29 (Taxation of Chargeable Gains Act 1992, s. 16, 21, 28).
Whether court had jurisdiction to award costs of hearing before special commissioners.