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GDF Suez Teesside v HMRC

In GDF Suez Teesside v HMRC [2017] UKUT 68 (17 February 2017) the UT found that the accounting of the assignment of debt claims by Teesside to a wholly owned subsidiary Teesside Recoveries and Investments was GAAP compliant; but that FA 1996 s 84(1) required Teesside to bring into account for tax purposes a sum representing the value of the shares allotted to it in exchange for the assignment.

Teesside had transferred substantial debt claims (totalling over $1bn) that it held against the Enron group to a wholly owned subsidiary Teesside Recoveries which was incorporated and tax resident in Jersey. In its notification of the scheme under DOTAS Teesside had explained that the scheme worked by enabling a UK company to indirectly realise the value of an existing asset which has no carrying value under UK GAAP ‘without triggering an immediate tax...

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