COURT OF SESSION (FIRST DIVISION)–

8 AND 9 MARCH AND 1 APRIL 1977

HOUSE OF LORDS–

11 AND 12 JANUARY AND 15 FEBRUARY 1978

Corporation tax – Chargeable gains – Disposal by holding company of its shares in subsidiary company on condition that holding company waived repayment of its loans to the subsidiary – Whether consideration given for shares alone or shares and loans – Whether the loans were debts on a security and an allowable loss accrued – Whether the amount of the loans was an allowable deduction in computing the gain or loss on the disposal – Finance Act 1965 (c 25), Sch 7, para 11; Sch 6, paras 4(1) (b), 8.

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