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UK: Payments to settle regulatory investigation deductible; claim for cross-border group relief barred

Summaries of recent court decisions

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February 6, 2025

The KPMG member firm in the UK prepared reports on two recent court decisions:

  • The Court of Appeal held that payments made by the taxpayer to settle a regulatory investigation were not penalties and thus were fully deductible. Read a February 2025 report
  • The First-tier Tribunal held that the taxpayer’s claim for cross-border group relief was barred under section 127 of the Corporation Tax Act 2010 because the main purpose or one of the main purposes of the taxpayer’s arrangement was to claim tax losses of an acquired Irish subsidiary. Read a February 2025 report

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