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Shinelock Ltd v HMRC

In Shinelock Ltd v HMRC [2021] UKFTT 320 (TC) (7 September) the First-tier Tribunal (FTT) dismissed the company’s appeal against a closure notice charging corporation tax on a gain on the disposal of a property where the company had immediately paid the full amount of the gain to its shareholder and director (Mr A). The FTT rejected the company’s argument that the payment resulted in a non-trading loan relationship deficit which could be set off against the gain.

The company had bought the property using funding provided partly by a bank and partly by Mr A. By the time of the hearing HMRC accepted that there was a verbal agreement under which the company would pay the gain on the sale of the property to Mr A.

The company originally argued that the gain itself actually accrued to Mr A rather than to it as a company but...

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