Corporation tax – Losses – Relief Time-limit – Substantive Fairness – Judicial review-Claims for relief against other profits of same period-Claims refused-Whether estimated figures delivered within two-year time-limit constituted claims-Express claims made after expiry of time-limit-Previous late claims admitted without question-Whether Revenue wrongly refused claims-Income and Corporation Taxes Act 1970, s 177(2) and {10), Taxes Management Act 1970, s 1, Income and Corporation Taxes Act 1988, ss 393(2) and (11) and 393A(10).
Citations:
[1996] EWCA Civ 68 – TC – 205, [1994] STC 841, 68 TC 205, [1994] STI 1023, [1996] STC 681
Links:
Statutes:
Income and Corporation Taxes Act 1970
Jurisdiction:
England and Wales
Corporation Tax
Updated: 09 June 2022; Ref: scu.625425