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Decision Number: |
TC 05111 |
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Appellant:
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Investec Asset Finance PLC, Investec Bank PLC |
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Respondent:
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The Commissioners for Her Majesty's Revenue & Customs |
Chairmen / Special
Commissioners: |
Howard NOWLAN
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Date Of Decision:
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24/05/2016 |
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Main Category:
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INCOME TAX/CORPORATION TAX |
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Main Subcategory:
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Partnership |
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Notes:
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Corporation Tax – Purchase by financial dealers of substantial partnership interests in highly tax-positive leasing partnerships, followed by realisation or disposal of rental streams - Whether purchase price of partnership interests, and further contributions to the partnerships were income or capital expenditure and if not capital, whether they were incurred wholly and exclusively for trading purposes - Whether partnership profits distributed to the dealers were to be taken into account twice for tax purposes - closure notice issues - Double tax relief issues |
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Decision(s) to Download:
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TC05111.pdf 
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