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MJP Media Services Ltd v HMRC

In MJP Media Services Ltd v HMRC (CA – 28 November) a company (M) claimed a corporation tax deduction of almost £6.7m in relation to certain transactions with an associated company. HMRC rejected the claim and M appealed contending that the debt arose from ‘transactions for the lending of money’ which constituted a ‘loan relationship’ within the definition in FA 1996 s 81 (see now CTA 2009 ss 302 303). The First-tier Tribunal (FTT) rejected this contention and dismissed the appeal observing that ‘in claiming a tax relief the burden of proof is on the appellant and the standard of proof is the balance of probabilities’. The Tribunal noted that ‘the companies had apparently not retained copies of their bank statements’ and commented that ‘it is hard to understand why this basic documentation was not available to explain the transactions’. On the evidence ...

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