Ball UK Holdings v HMRC

Cathya Djanogly

In Ball UK Holdings v HMRC [2017] UKFTT 457 (2 June 2017) the FTT found that accounts had not been prepared in accordance with UK generally accepted accounting practice (GAAP) so that the tax loss the company had hoped to create was not established.

Ball was a US publicly listed company owning an international group of companies; and BUKH was a UK company indirectly owned by Ball US.

BUKH made and received loans to and from its subsidiaries and other Ball group companies which were sometimes refinanced. It undertook these activities in sterling with the exception of a short term loan in euros in 2002 and a derivative mentioned below. The interest rates on the loans it made and received were determined by UK prime rate or LIBOR.

At the end of 2006 on advice from PwC BUKH decided to implement a scheme to change its...

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