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First-tier Tribunal (Tax)
You are here: BAILII >> Databases >> First-tier Tribunal (Tax) >> Shinelock Ltd v Revenue & Customs (CORPORATION TAX - capital gain realised on sale of property) [2021] UKFTT 320 (TC) (07 September 2021)
URL: http://www.bailii.org/uk/cases/UKFTT/TC/2021/TC08261.html
Cite as: [2021] STI 2304, [2021] UKFTT 320 (TC)
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| 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 |