[2019] UKUT 0169 (TCC)

The Hon. Mr Justice Marcus Smith, Judge Guy Brannan

Decision released 5 June 2019

CORPORATION TAX – whether certain companies were resident outside the United Kingdom – residence outside the United Kingdom essential for tax planning – the test for “residence”

Development Securities plc [2019] BTC 518


This appeal relates to a tax avoidance scheme designed to increase the value of a capital loss by an amount equivalent to the indexation allowance that would otherwise have been lost (because the allowance would have increased the value of a pre-indexation loss).

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