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Decision Number: |
Spc 00636 |
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Appellant:
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Prudential Plc |
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Respondent:
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Her Majesty's Revenue & Customs |
Chairmen / Special
Commissioners: |
His Honour Stephen OLIVER QC
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Date Of Decision:
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11/09/2007 |
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Main Category:
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INCOME TAX/CORPORATION TAX |
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Main Subcategory:
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Profits |
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Notes:
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QUALIFYING CONTRACTS – Profits and losses – Front end payments under currency contracts – Whether qualifying payments – No – Whether to be allocated such that payments are included as “amounts B” – No – Whether currency contracts were entered into for unallowable purposes – Yes – Appeal dismissed – FA 1994 ss 151, 155 and 168A |
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Decision(s) to Download:
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Spc00636.doc 
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