Market leading insight for tax experts
View online issue

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...

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.