Tax analysis: The First-tier Tax Tribunal (FTT) dismissed the taxpayer’s appeal against a promoted avoidance scheme involving the issue of bonus shares carrying a right to substantially all of the returns on certain derivatives and the accounting requirement for the derivatives to be derecognised. The FTT found that Union Castle Mail Steamship Company Limited (Union Castle) had not suffered a loss and therefore no tax deduction was available for the debit in relation to the derivative contracts.
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