Gerald Montagu (Gide Loyrette Nouel) examines the recent decision in Barclays Bank Plc v HMRC.
At the height of the 2008 financial crisis Barclays was ‘desperate’ to avoid a bail-out by the UK government and was seeking to shore up its Tier-One capital base by raising an additional £3bn. The bargain that was eventually struck with Qatari investors involved a subsidiary of Barclays PLC (‘Barclays’) BB PLC issuing RCIs which constituted loan relationships and Barclays issuing warrants over its own shares in return for £3bn in cash. BB PLC sought to claim debits under the loan relationship rules for £800m representing the difference (so BB PLC claimed) between the £2.2bn cash received by BB PLC from the investors for the RCIs and a £800 capital contribution received from Barclays in...
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Gerald Montagu (Gide Loyrette Nouel) examines the recent decision in Barclays Bank Plc v HMRC.
At the height of the 2008 financial crisis Barclays was ‘desperate’ to avoid a bail-out by the UK government and was seeking to shore up its Tier-One capital base by raising an additional £3bn. The bargain that was eventually struck with Qatari investors involved a subsidiary of Barclays PLC (‘Barclays’) BB PLC issuing RCIs which constituted loan relationships and Barclays issuing warrants over its own shares in return for £3bn in cash. BB PLC sought to claim debits under the loan relationship rules for £800m representing the difference (so BB PLC claimed) between the £2.2bn cash received by BB PLC from the investors for the RCIs and a £800 capital contribution received from Barclays in...
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