Kellogg Brown & Root Holdings (UK) Ltd v Revenue and Customs Commissioners – WLR Daily

Kellogg Brown & Root Holdings (UK) Ltd v Revenue and Customs Commissioners [2010] EWCA Civ 118; [2010] WLR (D) 53

“For the purposes of capital gains tax in relation to associated companies, under s 286(5)(b) of the Taxation of Chargeable Gains Act 1992, a ‘group’ did not require any common purpose but was to be given its ordinary meaning of ‘collection’. Where shares were disposed of by the taxpayer to another company and the ultimate parent companies of each were ‘connected persons’ then the taxpayer and the acquiring company were sufficiently connected within s 18(3) of the 1992 Act for the capital loss on the disposal to be deductible only from chargeable gains arising on other disposals between the same two companies.”

WLR Daily, 25th February 2010

Source: www.lawreports.co.uk

Please note once a case has been fully reported in one of the ICLR series the corresponding WLR Daily summary is removed.

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