[2015] UKFTT 0097 (TC)

Judge Jonathan Cannan

Decision released 3 March 2015

Corporation tax – Chargeable gains – Group relief – Taxation of Chargeable Gains Act 1992 (‘TCGA 1992’), s. 170, 171 – Tax avoidance scheme – Ramsay principle – Purposive construction of the group relief provisions – Whether the transactions fell within the group relief provisions – Appeal allowed.

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