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Ball UK Holdings Ltd v CRC, Upper Tribunal (Tax and Chancery Chamber), 10 December 2018
Ball UK Holdings was a UK intermediate holding company indirectly owned by a US corporation Ball US. Ball UK’s activities were limited to holding the shares in its subsidiaries and borrowing from and making loans to group companies.
At the end of 2006 on advice from PwC Ball UK implemented a scheme to change its functional currency to dollars (anti-avoidance provisions were introduced in FA 2011 to counteract these arrangements). The aim of this was to trigger the right to move from statement of standard accounting practice (SSAP) 20 to financial reporting standard (FRS) 23. This would enable the company to make a tax loss...
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