FTTTx INCOME TAX – Losses – whether losses relating to purchase and resale of commercial properties by appellant attributable to appellant’s UK property business (s264 Income Tax (Trading and Other Income Act) 2005) or whether the losses were trading losses – losses were trading losses – whether ‘discovery amendment’ under s30B(1) Taxes Management Act 1970 (‘TMA 1970’) to partnership statement reclassifying trading losses as property losses fell within conditions in s30B(1) TMA (which required that profits that ought to be included had not been included or that profits were or had become insufficient) on basis ‘profit’ included negative amounts – s30B(1) TMA 1970 not applicable on this basis – appeal allowed in principle
Judges:
Swami Raghavan
Citations:
[2013] UKFTT 83 (TC)
Links:
Statutes:
Taxes Management Act 1970 30B(1), Income Tax (Trading and Other Income) Act 2005 264
Income Tax
Updated: 14 November 2022; Ref: scu.472281