This case concerned corporation tax and a chargeable gain arising from the disposal of a property. The issue was whether a payment made by the disposing company to its controlling party was deductible as a loan relationship debit or was instead a distribution. The Upper Tribunal held that the payment was a distribution and therefore was not deductible as a loan relationship debit. The Tribunal also considered whether the First-tier Tribunal had decided issues on the basis of arguments that had not been pleaded and the circumstances in which “new” issues may be raised at an FTT hearing. The appeal was dismissed.