United Kingdom Upper Tribunal (Tax and Chancery Chamber)

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You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> Travel Document Service & Anor v Revenue & Customs (Corporation tax – tax avoidance scheme) [2017] UKUT 45 (TCC) (07 February 2017)
URL: http://www.bailii.org/uk/cases/UKUT/TCC/2017/45.html
Cite as: [2017] STC 973, [2017] BTC 505, [2017] UKUT 45 (TCC)

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Travel Document Service & Anor v Revenue & Customs [2017] UKUT 45 (TCC) (07 February 2017)

Corporation tax – tax avoidance scheme – use of total return swap over shares in subsidiary to create a deemed creditor relationship – value of shares depressed by novating liability for large loans to subsidiary – whether loan relationships had unallowable purpose – whether debits attributable to unallowable purpose

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