In relation to an intra-group reorganisation that enabled the acceleration use of non-trading loan relationship deficits where the appellants agreed to increase the rate of interest on loans, the appellants were party to loan relationships for an unallowable purpose, but the amount of debit attributable to that unallowable purpose must be considered on a just and reasonable basis.

The five appellant companies were all members of the Kwik-Fit group of companies (Kwik-Fit Group). In September and October 2013, following the acquisition of the Kwik-Fit Group by Itochu Corporation, a number of intra-group receivables that had been incurred by the