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- Why it matters
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Article summary
Tax analysis: In Shinelock Ltd v HMRC, the First-tier Tax Tribunal dismissed the company’s appeal against a closure notice charging corporation tax on a gain on the disposal of a property where the company had immediately paid the full amount of the gain to its shareholder and director (Mr A). The Tribunal rejected the company’s argument that the payment resulted in a non-trading loan relationship deficit which could be set off against the gain.
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