Kwik-Fit Group Ltd v Revenue & Customs (CORPORATION TAX - loan relationships) [2021] UKFTT 283 (TC)
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
Cited in 3 later judgments