FTT denies cross-border group relief claim on main purpose grounds (Lloyds Asset Leasing v HMRC)
Tax analysis: In Lloyds Asset Leasing, the First-tier Tax Tribunal (FTT) dismissed the taxpayer’s appeal against HMRC’s disallowance of its cross-border group relief claim. The FTT found that the qualifying loss and precedence conditions in sections 119 and 121 of the Corporation Tax Act 2010 (CTA 2010) were satisfied in respect of the claim, however the relief was denied under CTA 2010, s 127 as the FTT found that it would not have arisen but for arrangements that had a main purpose of securing that relief.