Tax

UK Care No. 1 Ltd v Revenue and Customs (Corporation Tax - loan relationships - s.327 Corporation Tax Act 2009 - disallowance of imported losses - non-resident company becoming UK resident prior to early redemption of loan notes - whether "loss2 for the purposes of s.327 includes expenses incurred for the purposes of a loan relationship)

[2026] UKUT TCC 90Upper Tribunal (Tax & Chancery)2026

“UPPER TRIBUNAL Tax and Chancery Chamber Rolls Building, Fetter Lane London EC4A 1NL Heard On 25 And 26 November 2025Judgment Date: 24 February 2026 B e f o r e :”

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