“…mmissioners [2016] STC 747 and thedecision of the UT (Proudman J and Judge Bishopp) in Spritebeam Ltd v Revenue and Customs Commissioners [2015] UKUT 75 (TCC), [2015] STC 1222 (“Spritebeam”), before noting at [124]:…”
“… pay the awards (or, more properly, reallocate or transfer Special Capital to them on the recommendation of the Partnership). He relied on Spritebeam Ltd vHMRC [2015] STC 1222. That case concerned a tax avoidance scheme which was intended to avoid tax credits arising under a loan relationship. Company A lent money to Company B but in…”