Income tax – Company. The Upper Tribunal (Tax and Chancery Chamber) (the tribunal) allowed the appeal by Bupa Insurance Ltd (BIL), a wholly-owned subsidiary of Bupa Finance plc (BF), against a decision of the Revenue and Customs Commissioners rejecting BIL's claim for consortium relief pursuant to ss 402(3) and 406(1) of the Income and Corporation Taxes Act 1988. The tribunal decided that BF was 'beneficially entitled' to any distribution of profits available to equity holders so as to determine the 'relevant fraction' that should apply to limit the amount of loses of the surrendering company that could be set against the total profits of BIL.