Amanda Rowland and David Leibowitz look at the important decision of the House of Lords in Re Toshoku Finance UK plc [2002] UK HL6
Toshoku Finance UK plc (Toshoku) was a subsidiary of a Japanese company that went into liquidation in December 1997. Toshoku went into liquidation on 26 January 1998.
Its principal asset was a debt of $156.3 million owned to it by TEE a fellow subsidiary of the Japanese parent. As TEE was insolvent Toshoku agreed to accept $21.5 million in full and final settlement of its debt but nothing was paid in respect of interest that had accrued on the debt after the commencement of winding up.
Under the loan relationship regime in Finance Act 1996 corporation tax is payable on interest...
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Amanda Rowland and David Leibowitz look at the important decision of the House of Lords in Re Toshoku Finance UK plc [2002] UK HL6
Toshoku Finance UK plc (Toshoku) was a subsidiary of a Japanese company that went into liquidation in December 1997. Toshoku went into liquidation on 26 January 1998.
Its principal asset was a debt of $156.3 million owned to it by TEE a fellow subsidiary of the Japanese parent. As TEE was insolvent Toshoku agreed to accept $21.5 million in full and final settlement of its debt but nothing was paid in respect of interest that had accrued on the debt after the commencement of winding up.
Under the loan relationship regime in Finance Act 1996 corporation tax is payable on interest...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
