Explainaway Limited, Quartfed Limited and Parastream Limited v The Commissioners for HM Revenue and Customs: [2012] UKUT 362 (TCC)
Upper Tribunal Tax & Chancery decision of Mr Justice Newey and Judge Sinfield on 19 October 2012.
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CORPORATION TAX 鈥� scheme to avoid tax on chargeable gains 鈥� whether derivative transactions gave rise to chargeable gains and losses 鈥� whether loss arising on disposal of shares in group company was an allowable loss 鈥� ICTA, s 128, and TCGA, ss 2 and 143 鈥� application of Ramsay principle.