HMRC successful in case Syngenta Holdings Ltd v HMRC

The judgment in Syngenta Holdings Ltd v HMRC has just been released. The case concerned the application of the unallowable purpose rules to intra-group lending arrangements. The case was heard over 5 days and involved a huge amount of documents and  extensive cross-examination. The decision will be of particular interest to corporate tax lawyers. HMRC was successful with its counsel team being led by Francis Fitzpatrick KC.