Tax Debits on Syngenta’s $950 Million Loan Denied by UK Court

A UK court denied an agricultural technology company’s claim for corporation tax debits on an intra-group loan of nearly $1 billion because the arrangement was used to reduce the company’s tax bill.

The UK’s First-tier Tribunal, in a Nov. 1 decision published Tuesday, upheld His Majesty’s Revenue & Customs’ rejection of deduction claims on a $950 million loan by Syngenta’s UK subsidiaries under the “unallowable purpose” rule.

The unallowable purpose rules apply when a company becomes party to a loan relationship where one of its main purposes is to secure a tax advantage.

The dispute centers on ...