FTTTx CORPORATION TAX – declaration under s.153A TCGA 1992 (business assets roll-over relief) ceasing to have effect – s.153A(4) providing that all necessary adjustment shall be made – whether that provides for a ‘free-standing’ power or alternatively incorporates a reference to the assessment and amendment powers in Sch. 18, FA 1998 – held s.153A(4) TCGA incorporates such a reference – HMRC’s decision under s.153A(4), the subject of the appeal, purporting to be an amendment to the Appellant’s self-assessment in its company tax return, of no effect as no power under Sch. 18 FA 1998 enabled the making of it – there being no provision for an appeal against that decision, the Tribunal had no jurisdiction to entertain the appeal and the appeal is therefore struck out
[2016] UKFTT 330 TC
Bailii
England and Wales
Corporation Tax
Updated: 17 January 2022; Ref: scu.564820