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Two Out of Three Ain't Bad

Peter Rayney BDO's National Tax Technical Partner says that The Court of Appeal judgment in Johnston Publishing raises more questions than it answers
After much waiting with bated breath on our part the Court of Appeal has just released its findings on the application of the associated companies' degrouping exemption in Johnston Publishing (North) Ltd v HMRC [2008] EWCA Civ 858. (The appeal was heard in late February 2008 and clearly must have caused some angst since the judgment was not released until five months later.)
It was a majority verdict with two out of three judges finding for HMRC. This seems to echo the sentiments expressed in Meat Loaf's classic pop ballad 'Two out of three ain't bad'. But since only a single statutory provision was being...

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