AH Field (Holdings) Ltd v HMRC

In AH Field (Holdings) Ltd v HMRC (TC01800 – 27 February) a UK company (H) was a subsidiary of another UK company (OI) which in turn was owned by a Jersey company (J). It sought the advice of accountants on ‘maximising the movement of funds from the UK to Jersey’. In December 2003 H borrowed £2 000 000 from a bank in order to pay a dividend of £1 999 500 to OI which in turn declared a similar dividend which it paid to J. Four days later H borrowed £1 999 500 from J and used this to repay the bank. H agreed to pay J £2 150 000 after 363 days. The companies entered similar transactions in subsequent years and H claimed a deduction for the difference between the amount it had borrowed from J and the amount repayable to J. HMRC...