Shinelock Limited v The Commissioners for HM Revenue and Customs [2023] UKUT 00107 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Thomas Scott and Judge Asley Greenbank on 15 May 2023
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CORPORATION TAX – chargeable gain on disposal of property – whether payment made by disposing company to controlling party was a deductible loan relationship debit – whether such payment was a distribution – whether FTT decided issues on basis of arguments which had not been pleaded – raising “new” issues in an FTT hearing – appeal dismissed