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Late claim for non-trading loan relationship deficit fails (Shinelock)

Published on: 19 October 2021
Published by a LexisNexis Tax expert

Table of contents

  • Why it matters
  • Case details

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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