In Marine Midland Ltd1, the taxpayer company carried on a banking business in various currencies, taking its profits from the differential between the interest it received on the money it lent and the interest it had to pay on its own borrowing to fund those loans. The company did not speculate in currency exchange transactions. Its policy was to minimise the risk of exchange losses by matching, so far as possible, all its dealings in any one currency. The company borrowed US dollars in the form of loan stock redeemable in ten years, which was for the most part
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