This is an appeal by Unilever (UK) Holdings Ltd (“Unilever”), for whom Robert Venables QC and James Kessler have appeared.
Corporation tax – Computation of profits – Set off of loss against chargeable gains – Appellant company owning shares in other company – High Court sanctioning scheme of arrangement resulting in reduction of company’s capital and cancellation of preference shares – Appellant subsequently seeking its shares in company at a loss – Appellant selling shares in second company at a profit – Appellant seeking to set off loss against chargeable gains – Special commissioners dismissing appellant’s appeal against assessment of corporation tax – Whether cancellation of preference shares amounting to reorganisation – Whether reorganisation creating new holding – Taxation of Chargeable Gains Act 1992, s 126, Ch II of Pt IV, Sch 2.