GovWire

Read full decision in Kwik-fit Group Limited and others v HMRC final decision

CORPORATION TAX loan relationships- unallowable purpose test intra-group restructuring of debt whether FTT erred in holding utilisation of trapped losses (Non-Trade Relationship Deficits) in intermediate holding company was tax advantage no - whether FTT erred in finding tax avoidance purpose no FTTs attribution of debits to unallowable purpose upheld appellants and HMRCs appeal dismissed FTT Decision upheld