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Cadwalader, Wickersham & Taft LLP

Reap What You Sow – UK’s Unallowable Purpose Rule Considered Again

Cadwalader, Wickersham & Taft LLP on

In Syngenta Holding Limited v HMRC [2024] UKFTT 998 (TC) (“Syngenta”), the UK’s First-tier Tribunal (“FTT”) denied a deduction for interest on an intra-group loan on the basis that the loan had an unallowable purpose for the...more

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