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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) >> Spritebeam Ltd & Ors v Revenue & Customs & Ors [2015] UKUT 75 (TCC) (25 February 2015) URL: http://www.bailii.org/uk/cases/UKUT/TCC/2015/75.html Cite as: [2015] STC 1222, [2015] BTC 507, [2015] UKUT 75 (TCC)

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CORPORATION TAX — company lends money to another group company on terms that shares are paid to a different group company — is the value of the shares income of the lender under the loan relationship rules? — no, but only because of the effect of s. 80(5) of the Finance Act 1996 — is the value of the shares income of the share recipient? — yes — appeals dismissed.

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