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Cadbury Schweppes Plc and Another v Williams (Her Majesty’s Inspector of Taxes): CA 24 May 2006

The taxpayer made arrangement for the sale of securities in the form of loan notes with accrued income. It appealed a decision denying to the arrangement treatment of the full sum as capital. Held: The appeal failed. The agreements provided for irregular repayments, they did so with an apparent standard interest rate. The agreements fell … Continue reading Cadbury Schweppes Plc and Another v Williams (Her Majesty’s Inspector of Taxes): CA 24 May 2006

Forthright (Wales) Limited v A L Davies (HM Inspector of Taxes): ChD 18 Mar 2004

The inspector disallowed a claim for enterprise investment relief, saying that not all the funds raised were to be used for a qualifying purpose. Held: The proceeds of a share issue had been used in part to pay a dividend. The issue did not qualify. The inspector’s refusal yto authorise exemption was a decision refusing … Continue reading Forthright (Wales) Limited v A L Davies (HM Inspector of Taxes): ChD 18 Mar 2004

Acts

1267 – 1278 – 1285 – 1297 – 1361 – 1449 – 1491 – 1533 – 1677 – 1688 – 1689 – 1700 – 1706 – 1710 – 1730 – 1737 – 1738 – 1751 – 1774 – 1792 – 1793 – 1804 – 1814 – 1819 – 1824 – 1828 – 1831 – 1832 … Continue reading Acts

De Silva and Another, Regina (on The Application of) v Revenue and Customs: SC 15 Nov 2017

The appellants had entered into certain partnerships designed to mitigate liability too income tax by creating trading losses through investments in films. HMRC rejected the claims. HMRC then sought to backdate adjustments to the carry-back claims involved. The tax payers now appealed from findings that the adjustments were not outside the statutory time limit, saying … Continue reading De Silva and Another, Regina (on The Application of) v Revenue and Customs: SC 15 Nov 2017

Bbosa v Revenue and Customs: FTTTx 18 Jul 2014

FTTTx Income Tax – Repayment claim for 2008/09 – Whether outwith time-limit – Yes – Schedule 1AB Taxes Management Act 1970 – Application for strike-out under Rule 8(2) of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 – Application granted Citations: [2014] UKFTT 694 (TC) Links: Bailii Jurisdiction: England and Wales Income Tax Updated: … Continue reading Bbosa v Revenue and Customs: FTTTx 18 Jul 2014

Simpson v Revenue and Customs: FTTTx 14 Nov 2013

FTTTx Income tax – claim for repayment of supposedly overpaid tax – Schedule 1AB and 1A Taxes Management Act 1970 – HMRC issued closure notice rejecting the claim – appeal against HMRC’s rejection of claim – Tribunal not satisfied on the evidence that HMRC’s rejection of the claim was incorrect – appeal dismissed Citations: [2013] … Continue reading Simpson v Revenue and Customs: FTTTx 14 Nov 2013

Hadee Engineering Co Ltd and Others v Revenue and Customs: UTTC 17 Mar 2022

CORPORATION TAX, CAPITAL GAINS TAX, INCOME TAX – expenditure allowable under s38(1)(b) of TCGA 1992 – penalties imposed under s95 of TMA 1970 – interaction of s393A of ICTA 1988, paragraphs 58 and 59 of Schedule 18 FA 1998 and Schedule 1A of TMA 1970 in relation to carry back of losses for corporation tax … Continue reading Hadee Engineering Co Ltd and Others v Revenue and Customs: UTTC 17 Mar 2022

Takhar v Gracefield Developments Ltd and Others: SC 20 Mar 2019

The claimant appellant alleged that properties she owned were transferred to the first defendant under undue influence or other unconscionable conduct by the second and third defendants. The claim was dismissed. Three years later she claimed to set that judgment aside having been obtained by fraud. To support the allegation she brought evidence not available … Continue reading Takhar v Gracefield Developments Ltd and Others: SC 20 Mar 2019

Derry, Regina (on The Application of) v Revenue and Customs: SC 10 Apr 2019

D bought 500,000 shares in TY 2009/10 for pounds 500,000 in Media Pro Four Ltd. In tax year 2010/11 he sold them to ‘Island House Private Charitable Trust’ for pounds 85,500, realising a loss of pounds 414,500. His 2009/10 tax return claimed share loss relief for that amount against income for that year under section … Continue reading Derry, Regina (on The Application of) v Revenue and Customs: SC 10 Apr 2019

Derry, Regina (on The Application of) v HM Revenue and Customs: CA 20 Jun 2017

‘The structure of Schedule 1B is that it applies to certain specified claims for relief involving two or more years. The provisions relating to loss relief are contained in paragraph 2. The remaining paragraphs deal with entirely separate claims, for example relief for fluctuating profits of farming etc in paragraph 3, and the carry-back of … Continue reading Derry, Regina (on The Application of) v HM Revenue and Customs: CA 20 Jun 2017

Derry, Regina (on The Application of) v Revenue and Customs: UTTC 28 Jul 2015

UTTC Application for judicial review – self-assessment in annual return – claim to relief under Chapter 6 of Part 4 of Income Tax Act 2007 (dealing with share loss relief) – whether such a claim governed by section 42(11A) of, and Schedule 1B, to Taxes Management Act 1970 – whether any enquiry into claim should … Continue reading Derry, Regina (on The Application of) v Revenue and Customs: UTTC 28 Jul 2015

Scott v Revenue and Customs (Income Tax/Corporation Tax : Exemptions and Reliefs): FTTTx 27 Aug 2015

FTTTx INCOME TAX – HMRC determinations for 2006-07 and 2007-08 – Appellant’s Self-Assessment returns filed out of time to displace determinations – Illness and Death of previous accountant – Claim for Special Relief – Schedule 1AB Taxes Management Act 1970 – Nature of the Tribunal’s jurisdiction – Maxwell v HMRC [2013] UKFTT 459 (TC) and … Continue reading Scott v Revenue and Customs (Income Tax/Corporation Tax : Exemptions and Reliefs): FTTTx 27 Aug 2015

Sehgal v Revenue and Customs: FTTTx 19 Nov 2013

FTTTX CAPITAL GAINS TAX – Claim for relief for overpaid tax – Schedule 1AB Taxes Management Act 1970 – return showing disposal of shares giving rise to a chargeable gain – capital gains tax paid – taxpayer later claiming that the transaction was fraudulent and the capital gains tax should be repaid to her – … Continue reading Sehgal v Revenue and Customs: FTTTx 19 Nov 2013

Derry, Regina (on The Application of) v Revenue and Customs; UTTC 28 Jul 2015

References: [2015] UKUT 416 (TCC) Links: Bailii UTTC Application for judicial review – self-assessment in annual return – claim to relief under Chapter 6 of Part 4 of Income Tax Act 2007 (dealing with share loss relief) – whether such a claim governed by section 42(11A) of, and Schedule 1B, to Taxes Management Act 1970 … Continue reading Derry, Regina (on The Application of) v Revenue and Customs; UTTC 28 Jul 2015