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M Bamberg v HMRC

In M Bamberg v HMRC (TC00618 – 3 August) a company (T) with distributable reserves acquired a company (W) with negative reserves in May 2000. On the same day T’s controlling shareholder (B) acquired loan stock which W had issued. From May 2000 to 2002 T made loans to W following which W repaid some of the loan stock. In February 2002 T’s trade was hived down to W which made further repayments of loan stock to B. HMRC issued assessments on B on the basis that he had received a tax advantage by reason of a transaction in securities. The First-Tier Tribunal reviewed the evidence in detail and issued a decision in principle dismissing the appeal up to the amount of T’s distributable reserves until the hive-down of its trade but allowing the appeal in respect of any further profits made by W after the...

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