Revenue and Customs Commissioners v Bristol and West plc  BTC 18
 EWCA Civ 397
Court of Appeal (Civil Division)
Lady Justice Black, Lord Justice Briggs, and Lord Justice David Richards
Judgment delivered 27 April 2016
Corporation tax – Taxation of profits made on sale or transfer of derivatives under Finance Act 2002 to transferee in the same group – Transferor within the regime of FA 2002 but transferee not yet within that regime – Application of FA 2002, Sch. 26, para. 28 – Whether transfer disregarded for tax purposes – No – Whether adjustments to return precluded by issue of closure notice in error – No.