You cannot use an intra-group loan to obtain a tax advantage
The Court of Appeal (CoA) agreed with the HMRC that, where an intra-group loan results in an overall tax benefit to a group, then the unallowable purpose rule may need to be
The Court of Appeal (CoA) agreed with the HMRC that, where an intra-group loan results in an overall tax benefit to a group, then the unallowable purpose rule may need to be
Facts: Mr Kashif Ahmed and his sister, Ms Bushra Ahmed, were directors of Hornby Street Ltd, a company which arranged for the manufacture of clothing, footwear and headgear and