The FTT appeal focused on a single Lloyds subsidiary, Lloyds Asset Leasing Limited (LAL), and whether it was entitled to claim cross-border group relief (CBGR) for the accounting period ending 31 December 2010 in line with Chapter 3 of Part 5 and section 135 of Corporation Tax Act 2010 (CTA).

However, the decision affects numerous subsidiaries of Lloyds, which made the same CBGR claims, bringing the potential tax bill to £1,070,323,000.

Lloyds Asset Leasing Limited was just one of 100 subsidiaries of Lloyds Banking Group to whom Bank of Scotland Ireland (BOSI) sought to surrender losses it incurred in relation to its banking business in Ireland.