HEXAGON PROPERTIES LIMITED v Revenue & Customs (Corporation tax - loan relationships - Appellant sued bank for damages for mis-sold interest rate hedging product) [2022] UKFTT 137 (TC)
Notes: Corporation tax - loan relationships - Appellant sued bank for damages for mis-sold interest rate hedging product - litigation settled on basis that £3.5 million of existing debt to the bank was "released and discharged" by way of settlement of the damages claim - whether this amounted to a "related transaction" - yes - whether the £3.5 million potentially represented a "profit" for loan relationship purposes - yes - whether it arose to the Appellant from its loan relationships or related transactions - held no, it arose from the settlement of the underlying damages claim - therefore taxable under general principles rather than loan relationship regime - appeal allowed
Cited in 2 later judgments