[2014] UKFTT 175 (TC)

Judge Colin Bishopp

Decision released 20 February 2014

Income tax – Loss relief – Admitted avoidance scheme – Whether trade existed – No – If existed, when begun – Whether manufactured payment representative of overseas dividend – No – Whether payment an incidental cost of obtaining finance – No – Scheme unsuccessful – Whether if scheme succeeded it would fail on Ramsay principles – Yes – Appeals dismissed

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