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United Kingdom Upper Tribunal (Tax and Chancery Chamber)
You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> GDF Suez Teesside Ltd v Revenue and Customs (CORPORATION TAX) [2017] UKUT 68 (TCC) (17 February 2017)
URL: http://www.bailii.org/uk/cases/UKUT/TCC/2017/68.html
Cite as: [2017] UKUT 68 (TCC), [2017] STC 1622, [2017] BTC 507
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GDF Suez Teesside Ltd v Revenue and Customs (CORPORATION TAX) [2017] UKUT 68 (TCC) (17 February 2017)
CORPORATION TAX avoidance scheme transfer of contingent, unrecognised, claim against third party to subsidiary in exchange for shares subsidiary recognising value of asset despite contingency but parent not recognising shares whether accounting GAAP-compliant yes loan relationship rules whether FA 1996 s 84(1) engaged yes recognised value of asset to be brought into account as credit in parents corporation tax computation appeal dismissed PROCEDURE opening of enquiry whether error in identification of accounting period invalidates enquiry no, if intention clear.
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