Market leading insight for tax experts
View online issue

JTI Acquisition Company (2011) Ltd v HMRC

In JTI Acquisition Company (2011) Ltd v HMRC [2024] EWCA Civ 652 (13 June) the Court of Appeal (CA) dismissed the taxpayer’s appeal against the disallowance for corporation tax purposes of debits in respect of interest payable on loan notes. The CA agreed with the First-tier Tribunal (FTT) and the Upper Tribunal (UT) that the taxpayer was party to the loan notes for an unallowable tax avoidance purpose under the loan relationships rules and not for any commercial purpose.

JTI Acquisition Company (2011) Ltd (JTIAC) the appellant was a UK-resident company newly incorporated by a US group for use as an acquisition vehicle. The US group had entered into a commercial agreement to acquire another US-headed group (LTT) for $1.1bn. JTIAC raised half of the purchase price through debt pushed down from the US effected by JTIAC issuing interest-bearing loan notes to a US member of its...

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.