[2002] EWCA Civ 1869.

Court of Appeal (Civil Division).

Schiemann, Arden and Dyson L JJ.

Judgment delivered 20 December 2002.

Corporation tax – Receipt – Income or capital – Rent factoring scheme – Taxpayer owned properties let to ultimate group holding company – Assignment of future rent in return for discounted lump sum – Whether payment was income or capital receipt – Taxation of Chargeable Gains Act 1992, s. 175.

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