Swiss Centre Ltd v HMRC [2026] UKUT 227: HMRC Kills a £34 Million Deduction — What Every CFO Must Know About Loan Relationships, Guarantor Payments and Unallowable Purpose
The Upper Tribunal has handed HMRC a comprehensive win in Swiss Centre Ltd v HMRC [2026] UKUT 227, confirming that a £34 million payment taken to P&L was not deductible for corporation tax — not under the loan relationship rules, not as capital enhancement expenditure. Six CFO actions before your next group finance review.

