Reap What You Sow – UK’s Unallowable Purpose Rule Considered Again
JD Supra: Mergers
JANUARY 22, 2025
In Syngenta Holding Limited v HMRC [2024] UKFTT 998 (TC) (Syngenta), the UKs First-tier Tribunal (FTT) denied a deduction for interest on an intra-group loan on the basis that the loan had an unallowable purpose for the purposes of section 411 of the Corporation Tax Act 2009 (CTA 2009). By: Cadwalader, Wickersham & Taft LLP
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