The Union Castle Mail Steamship Company Ltd and The Commissioners for HM Revenue and Customs: [2018] UKUT 0316 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Fancourt and Judge Berner on 2 October 2018.

• From: HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
• Published: 2 October 2018

• Category: Tax
• Release date: 2 October 2018

Read the full decision in The Union Castle Mail Steamship Company Ltd and The Commissioners for HM Revenue and Customs: [2018] UKUT 0316 (TCC).

CORPORATION TAX – derivative contracts – issue of bonus A Shares carrying a right to a dividend transferring 95% of economic benefit of financial options – derecognition of financial asset (IAS 39) – whether the accounting debit consequent upon derecognition fairly represents for the accounting period in question losses which arise to the company from its derivative contracts – FA 2002, Sch 26 – whether transfer pricing provisions were applicable – ICTA, Sch 28A; FA 2002, Sch 26, para 31A – whether requirements of FA 2002, para 15 must be met in a case where para 25A applies.

Published 2 October 2018