Land Securities has lost a court battle with HM Revenue & Customs (HMRC) over its use of a Morgan Stanley backed tax avoidance scheme.
HMRC said the taxpayer would have been £60m out of pocket if the scheme had continued. Land Securities, a FTSE 100 company, sold shares in one of its group companies to a Cayman Island subsidiary of US investment bank Morgan Stanley, which then inflated the value of the shares by pumping money into the subsidiary, HMRC said. Land Securities bought back the shares at the inflated price, claiming that the effect of an existing anti-avoidance rule was that they had made a "loss" of £200m that could be used as a deduction against tax. In a tribunal the company claimed that disallowing ...
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