The Commissioners for HM Revenue and Customs v Smith and Nephew Overseas Ltd and Others: [2018] UKUT 0393 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Fancourt and Judge Thomas Scott on 29 November 2018.
Read the full decision in .
CORPORATION TAX – change in functional currency following reorganisation – whether relevant accounts complied with UK generally accepted accounting practice – yes – whether “exchange losses” arose – yes – whether exchange differences fairly represented losses arising to the company under Finance Act 1996, s.84(1) – yes – appeal dismissed.