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Income tax – Corporation tax. The Revenue had repaid overpaid VAT plus interest to the taxpayer, both of which amounted to significant sums. The Revenue then charged the payments to corporation tax. The taxpayer had unsuccessfully sought to challenge that decision. The Court of Appeal, Civil Division, dismissed the taxpayer's appeal as the VAT element of the repayment had been chargeable to corporation tax pursuant to s 103(1) of the Income and Corporation Taxes Act 1988 and the interest had been chargeable as a 'qualifying loan relationship' within the meaning of s 100 of the Finance Act 1996.
Income tax – Corporation tax. The Revenue had repaid overpaid VAT plus interest to the taxpayer, both of which amounted to significant sums. The Revenue then charged the payments to corporation tax. The taxpayer had unsuccessfully sought to challenge that decision. The Court of Appeal, Civil Division, dismissed the taxpayer's appeal as the VAT element of the repayment had been chargeable to corporation tax pursuant to s 103(1) of the Income and Corporation Taxes Act 1988 and the interest had been chargeable as a 'qualifying loan relationship' within the meaning of s 100 of the Finance Act 1996.
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