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Travel Document Service & Ladbroke Group International v HMRC

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In Travel Document Service & Ladbroke Group International v HMRC [2018] EWCA Civ 549 (20 March 2018) the Court of Appeal found that debits under a loan relationship were not allowable under FA 1996 Sch 9 para 13.

TDS and LGI both belonged to the Ladbroke group of companies. TDS was a subsidiary of Ladbrokes plc the group's parent company and itself owned LGI. LGI in turn held the shares in a company with two trading subsidiaries JBB and LCC. JBB was the lessee of numerous properties and LCC provided call centre services. The principal operating company of the group was LBG another subsidiary of Ladbrokes plc. It had as a subsidiary LNIH which itself owned a company based in Northern Ireland NWB.

The group had implemented a scheme to generate...

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