In the Upper Tribunal, Rebecca Sheldon alongside Elizabeth Wilson KC acted for the Respondents, HMRC. This appeal questioned a previous decision made in the FTT, which held that a loan had unallowable purposes under sections 441 and 442 of the Corporation Tax Act 2009. The UT affirmed the previous decision of the FTT and dismissed this appeal. It is evident in the ratio decidendi of this case, that the UT agreed with many of the findings of the FTT and that the errors that were previously made in interpreting “related transactions” and attribution were deemed immaterial to the overall decision. For more information on this case, please view the judgment.