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Upper Tribunal tax appeal on imported losses and loan relationship debits. It held section 327 can apply to expenses, but allowed relief for unamortised issue costs and discount.
The portion of the loss claimed by UKC1 that reflects changes in market conditions and unamortised issue costs prior to migration is referable to the pre-migration period and is disallowed under section 327 CTA 2009. The penalty element arising from the early redemption decision post-migration is not referable to the pre-migration period and is allowable. Section 327 applies to both losses and expenses.
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