Court of Appeal (Civil Division).

[The appeal against this decision is reported at [2002] BTC 69.]

Sir Richard Scott V-C, Chadwick and Buxton LJJ.

Judgment delivered 23 March 2000.

Corporation tax – company liquidation – Priority of claims – Creditors’ voluntary liquidation – Interest due to company on loan made to another member of the group – Whether tax liability arising from a ‘loan relationship’ on interest payable but not paid was an expense of liquidation – Insolvency Act 1986, s. 115; Finance Act 1996, s. 80, 84; Insolvency Rules 1986, r. 4.218.

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