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INTERNATIONAL U.K. House of Lords

Aberdeen Construction Group Ltd v Inland Revenue Commissioners [1978] UKHL TC_52_281 (15 February 1978)

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Aberdeen Construction Group Ltd v Inland Revenue Commissioners [1978] UKHL TC_52_281 (15 February 1978)

Corporation tax – Chargeable gains – Disposal by holding company of its shares in subsidiary company on condition that holding company waived repayment of its loans to the subsidiary – Whether consideration given for shares alone or shares and loans – Whether the loans were debts on a security and an allowable loss accrued – Whether the amount of the loans was an allowable deduction in computing the gain or loss on the disposal – Finance Act 1965 (c 25), Sch 7, para 11; Sch 6, paras 4(1) (b), 8.
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