[2014] UKFTT 151 (TC)

Judge Michael S Connell; Dr Caroline J Small.

Decision released 30 January 2014.

Corporation tax – Deemed charge under ICTA 1988, s. 419 on loan to participator – Investment in close company – Shareholder agreement – Subscription for shares payable by instalments – Instalments not paid – Whether loan to participator – No – Appeal allowed.

  The FTT has found that an amount owing to a company in respect of share capital paid for in instalments did not give rise to a tax charge for the company under ICTA 1988, s. 419 (now CTA 2010, s. 455).


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