INTM435060 - Transfer pricing: tax cases - Ametalco v CIR (SpC94)

The 1996 Special Commissioners’ decision in Ametalco UK & Ametalco Ltd v CIR confirmed the view that financial facilities such as loans come within the scope of “business facilities of whatever kind” in ICTA88/S773(4).

The case is discussed in more detail at INTM501050.

And guidance on the application of ICTA88/S770 to outward loans not at arm’s length (for accounting periods ending on or before 30 June 1999) can be found at INTM501040.