HMRC has beaten Versteegh, Commercial Estates Group and Westbury at the First Tier Tribunal (FTT) in a case involving a complex tax avoidance scheme which replaced interest on a loan between two companies in the same group with shares issued to a third entity. This is the lead case appeal for groups which entered into a tax avoidance scheme designed to create a deduction in one group company for an intragroup loan without giving rise to taxable income in another. The lead appellant was Versteegh Ltd, the property developer and estate management company owned by Swedish multimillionaire Gerard Versteegh, represented by PwC Legal.
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