|
Decision Number: |
TC 08493 |
|
Appellant:
|
JTI ACQUISITION COMPANY (2011) LIMITED |
|
Respondent:
|
Her Majesty's Revenue & Customs |
Chairmen / Special
Commissioners: |
Dr Heidi POON
|
|
Date Of Decision:
|
19/04/2022 |
|
Main Category:
|
PROCEDURE |
|
Main Subcategory:
|
Other |
|
Notes:
|
CORPORTION TAX – sections 441 and 442 CTA 2009 – whether non-trade loan relationship debits to be disallowed – UK company incorporated to be the holding company to acquire a US group by stock purchase – cross-jurisdiction intercompany loan between US parent and UK holding – whether the loan relationship had an ‘unallowable purpose’ – whether securing a ‘tax advantage’ was not the main or one of the main purposes – whether attribution on a just and reasonable basis – appeal dismissed |
|
Decision(s) to Download:
|
TC 08493.pdf 
|
