Bylined article by London Tax partner Sandy Bhogal on the Farnborough Airport v HMRC case which held that the appointment of a receiver constitutes change of control for corporation tax group relief purposes.
Due to an error in the tribunal case report, Farnborough Airport Properties Company and Farnborough Properties Company were erroneously referred to with the addition of “Ltd” after their names. We understand that they are in fact private unlimited companies, albeit with issued share capital. This is not considered to have a material impact on the analysis in the article.
This was first published in Tax Journal on 25 July 2016