[2018] EWCA Civ 2075

Court of Appeal (Civil Division)

Lord Justice Henderson, Lady Justice Asplin and Lord Kitchin

Judgment delivered 5 October 2018

Corporation tax – Avoidance scheme – Transfer to subsidiary of contingent, unrecognised, claim against third party in exchange for shares – Subsidiary recognising value of asset despite contingency but parent not recognising shares – Loan relationship rules – Whether FA 1996, s. 84(1) engaged – Yes – Recognised value of asset to be brought into account as credit in parentʼs corporation tax computation – Appeal dismissed.

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