4 New Square Chambers’ Emile Simpson, led by Francis Fitzpatrick KC and with Thomas Chacko, successfully represented HMRC in Syngenta Holdings Ltd v HMRC [2024] UKFTT 998 (TC).
This high-value Corporation Tax case concerned the application of the unallowable purpose rules in the context of a loan of $950m which formed part of the consideration for a ca. $2.2bn acquisition of another group company by the Appellant.
The case is reported in Tax Journal and Bloomberg Law.
