[2014] UKUT 0073 (TCC).

Upper Tribunal (Tax and Chancery Chamber).

Croner-i understands this decision is to be appealed.

Mr Justice Peter Smith

Decision released 14 February 2014.

Taxation of profits made on sale or transfer of derivatives under Finance Act 2002 (‘FA 2002’) – Whether transfer disregarded between subsidiaries where one of the companies is not subject to the regime under the 2002 Act – Closure Notice – Whether effective when sent by mistake known to the tax payer company.

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