Ball UK Holdings v HMRC

Cathya Djanogly

In Ball UK Holdings v HMRC [2018] UKUT 407 (10 December 2018) the UT upheld the FTT’s finding that the company had not changed its functional currency according to GAAP.

Ball UK Holdings (Ball UK) is a UK intermediate holding company indirectly owned by a US corporation Ball US. It was set up in 2002 to hold certain UK subsidiaries acquired by Ball US as part of an acquisition of another group. Ball UK’s activities were limited to holding the shares in its subsidiaries and borrowing from and making loans to group companies including its subsidiaries. In 2005 in order to change its functional currency from sterling to dollars it entered into a derivative contract with a group member. This gave Ball UK the ability to choose to apply fair value accounting. The exercise of that choice in turn triggered a requirement to comply...

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