[2014] UKFTT 182 (TC)

Judge Kevin Poole

Decision released 12 February 2014.

Corporation tax – Corporate underwriter at Lloyd’s – Application of anti-loss buying restriction to group relief in Finance Act 1994, s. 227A – Whether losses sought to be surrendered were ‘losses of the last active underwriting year’ – whether ‘group-relief continuity condition’ satisfied – interpretation of commencement provision applying s. 227A – appeal allowed

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