Court of Appeal hand down decision in Union Castle case

The Court of Appeal has handed down its decision in Union Castle, upholding the UT’s decision that a derecognition in the accounts of the value of derivative contracts does not give rise to an allowable loss for corporation tax purposes. The Court of Appeal did not address the transfer pricing issue that arose in this case. The appeal of Union Castle has been remitted to the FTT to determine the tax computation following the decision of the Court of Appeal.

Jonathan Peacock QC and Sarah Black acted for the taxpayers.