House of Lords.

Lord Nicholls of Birkenhead, Lord Hoffmann, Lord Hope of Craighead, Lord Hutton, Lord Hobhouse of Woodborough.

Judgment delivered 8 February 2001.

Tax avoidance – Corporation tax – Tax mitigation – Allowance of charges on income – Taxpayer making payments of accrued interest by means of further loans from creditor – Creditor owning indirectly issued shares of taxpayer – Whether payment of interest by taxpayer – Income and Corporation Taxes Act 1988, ss. 75(3), 338, 787(1).


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