THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS v RAJ SEHGAL (1) SANJEEV MEHAN (2) [2024] UKUT 00074 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Adam Johnson and Judge Kevin Poole on 25th March 2024
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Remittance of foreign gains – s 809L ITA 2007 – indemnity liability waived and UK inter-company debt not pursued pursuant to payment by non-UK third party overseas in separate transaction financed by taxpayers using proceeds of offshore chargeable gains – whether service provided or money used in the UK – whether money or consideration for service were or were derived from the gain – whether money used in UK was the gain – whether money that was or was derived from chargeable gains was used outside the UK in respect of a relevant debt