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Corporation Tax - (a) was the Appellant a debtor under a loan relationship; (b) had the Appellant made a loan to a participator within s455 CTA 2010
The hearing took place on 31 March 2021 . With the consent of the parties, the form of the hearing was by the Tribunal video platform. A face to face hearing was not held because of the Covid 19 pandemic.
Prior notice of the hearing had been published on the gov.uk website, with information about how representatives of the media or members of the public could apply to join the hearing remotely in order to observe the proceedings.� As such, the hearing was held in public.
WT Banks & Co (Farming) Ltd (�WTB�) owns farmland and is engaged in farming in the North of England. Mr Stuart Banks is a director and a major shareholder. Between 2014 and 2016 WTB made a series of payments to or for the benefit of Solar Energy Parks Ltd (�SEL�), a company in which Mr Banks had a 50% shareholding.
SEP was struck off the Companies House register in June 2016 for failing to submit accounts. In its tax return for the year ended 30 June 2016 WTB recognised a deduction under the loan relationship provisions from its taxable profits as the result of making a bad debt provision in respect of a loan made to SEP, being the amount of the sums paid to or for the benefit of SEP since 2014.
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