[2016] UKFTT 0356 (TC)

Judge Howard M. Nowlan, Elizabeth Bridge

Decision released 24 May 2016

Corporation tax – Purchase by financial dealers of substantial partnership interests in highly tax-positive leasing partnerships, followed by realisation or disposal of rental streams – Whether purchase price of partnership interests, and further contributions to the partnerships were income or capital expenditure and if not capital – Whether they were incurred wholly and exclusively for trading purposes – Whether partnership profits distributed to the dealers were to be taken into account twice for tax purposes – Closure notice issues – Double tax relief issues.

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