[2017] UKUT 45 (TCC)

Upper Tribunal (Tax and Chancery Chamber)

[The appeal against this decision is reported at [2018] BTC 13.]

The Hon Mr Justice Arnold and Judge Timothy Herrington

Decision released 7 February 2017

Corporation tax – Tax avoidance scheme – Use of total return swap over shares in subsidiary to create a deemed creditor relationship – Value of shares depressed by novating liability for large loans to subsidiary – Whether loan relationships had unallowable purpose – Whether debits attributable to unallowable purpose.

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