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Upper Tribunal Tax and Chancery Chamber
UT (Tax & Chancery) UT/2022/0092 - [2024] UKUT 00373 (TCC)
Fecha: 29-May-2024
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- Heading
- Introduction
- FTT Decision
- Relevant legislation
- Grounds of appeal
- Ground 1 – whether the transaction forms part of arrangements of which one of the main purposes is the avoidance of liability to tax such that group relief is unavailable
- Tower One’s submissions
- No tax was actually avoided
- Any avoidance was of a future or contingent liability to tax
- Confusion of intended effect with purpose
- Any tax avoidance purpose was not a main purpose
- Discussion and conclusion
- Ground 2 – whether the Case 3 exception to the deemed market value rule applies
- Tower One’s submissions
- HMRC’s submissions
- Conclusions