[2014] EWCA Civ 1302

Court of Appeal (Civil Division)

Lord Justice Gross, Lord Justice Lewison, Lord Justice Underhill

Judgment delivered 30 October 2014

Corporation tax – Whether the profit on loan notes is subject to the charge to corporation tax under the loan relationship rules – Construction of Finance Act 1996 (‘FA 1996’), s. 84(2)(a) and Sch. 9, para. 12 – Profit appropriated to share premium account was excluded from the scope of FA 1996, s. 84(2)(a) by Sch. 9, para. 12 – Appeal dismissed.

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