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news-tc-CRC v Bank of Ireland Britain Holdings Ltd

22 August 2007
Categories: Tax cases , Admin

Unreal world

Unreal world

The case concerned whether or not a tax avoidance scheme succeeded in making a loss where the taxpayer had not made a commercial loss. The scheme involved a repo. This consisted of three parties and dividends were paid on the securities during the four months it operated i.e. November 2000 to March 2001. The loss if the scheme worked was equivalent to the dividends paid (£3.6 million) to the Bank of Ireland while it owned the relevant securities. That amount also comprised most of a 'manufactured overseas dividend' of some £358 151 which was deemed to have been paid to the taxpayer and which the taxpayer could deduct as a charge on income in computing taxable profits under TA 1988 s 737A.
It was accepted that the taxpayer was entitled to a deduction for the full amount of approximately...

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