[2014] UKFTT 982 (TC)

Judge Greg Sinfield, Ian Menzies Conacher ACIB, CTA, FCA

Decision released 23 October 2014

Corporation tax – Deemed loan transactions under the Income and Corporation Taxes Act 1988 (‘ICTA 1988’), s. 730A – Whether effect of the Finance Act 2003 (‘FA 2003’), s. 195 that acquisition of own shares disregarded for purposes of s. 730A – No – Alternatively whether the Finance (No 2) Act 2005 (‘F(No 2)A 2005’), s. 27 applies in relation to £214,108,391 paid by BCHL to BJL on 25 September 2008 – No – Appeal dismissed.

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