Wednesday 26 – Thursday 27 October 2022
By Appellant’s Notice filed on 1 November 2021, HMRC appeal the decision of Mr Justice Fancourt and Upper Tribunal Judge Jonathan Cannan, dated 18 August 2021.
Factual Background: Centrica Overseas Holdings Limited (“COHL”) is an investment holding company. It is a subsidiary of GB Gas Holdings Limited, which is itself a subsidiary of Centrica Plc. In 2020 the First Tier Tribunal dismissed COHL’s appeal against HMRC’s decision that Centrica was not entitled to claim corporation tax relief for certain expenses, which COHL said were said to be expenses of management of its investment business totalling some £2.5m claimed under s.1219 of the Corporation Tax Act 2009. The Upper Tribunal reversed the decision of the First Tier Tribunal.