Decision Number: | TC 08261 |
Appellant: | Shinelock Ltd |
Respondent: | The Commissioners for Her Majesty's Revenue & Customs |
Chairmen / Special Commissioners: |
Jeanette Zaman |
Date Of Decision: | 07/09/2021 |
Main Category: | PROCEDURE |
Main Subcategory: | Other |
Notes: | CORPORATION TAX - capital gain realised on sale of property - whether payment to director/former shareholder who was controlling party was deductible - jurisdiction in circumstances where no claim made to use loan relationship deficit before issue of closure notice or expiry of two year time limit - whether payment was a distribution - whether amount deductible as expense or loss from non-trading loan relationship - appeal dismissed |