[2014] UKUT 0454 (TCC)

Upper Tribunal (Tax and Chancery Chamber)

CCH understands this decision is to be appealed.

Mr Justice Barling, Mr Charles Hellier

Decision released 13 November 2014

Procedure – Appeal against closure notice – Reliance on grounds for amendment not stated in closure notice – R & C Commrs v Tower MCashback LLP 1 [2011] BTC 294 considered.

Corporation tax – Loan relationships – Application of Finance Act 1996 (‘FA 1996’), Sch. 9, para. 13 to debit arising under FA 1996, Sch. 9, para. 19A.

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