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First-tier Tribunal (Tax)
You are here: BAILII >> Databases >> First-tier Tribunal (Tax) >> Kwik-Fit Group Ltd v Revenue & Customs (CORPORATION TAX - loan relationships) [2021] UKFTT 283 (TC) (11 August 2021)
URL: http://www.bailii.org/uk/cases/UKFTT/TC/2021/TC08226.html
Cite as: [2021] STI 2057, [2022] SFTD 193, [2021] UKFTT 283 (TC)
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| Decision Number: | TC 08226 |
| Appellant: | Kwik-Fit Group Limited |
| Respondent: | The Commissioners for Her Majesty's Revenue & Customs |
|
Chairmen / Special Commissioners: |
Jeanette Zaman |
| Date Of Decision: | 11/08/2021 |
| Main Category: | PROCEDURE |
| Main Subcategory: | Other |
| Notes: | CORPORATION TAX - loan relationships - unallowable purpose test - intra-group reorganisation enabled acceleration of use of non-trading loan relationship deficit - Appellants agreed to increase rate of interest on loans - whether Appellants were party to loan relationships for an unallowable purpose - held yes - consideration of amount of debit attributable to that unallowable purpose on a just and reasonable basis - appeal allowed in part |