Income tax – Corporation tax. The First Tier Tribunal (Tax Chamber) and the Upper Tribunal (Tax and Chancery Chamber) had been correct to conclude that the credits which had to be brought into account by the taxpayer company, in respect of the transfer of unrealised claims to a Jersey subsidiary in return for shares in that subsidiary, were the sums shown as the value of the consideration shares in the assignments, and not a nil amount. Accordingly, the Court of Appeal, Civil Division, dismissed the taxpayer's appeal against closure notices altering tax due, issued against it by the Revenue and Customs Commissioners.