PROCEDURE – enquiry into returns made following automated notice requiring return – whether s12D TMA 1970 applies to treat notice of enquiry under s9A TMA 1970 and closure notice under s28A TMA 1970 as valid – yes – appeal dismissed CAPITAL GAINS TAX – entrepreneurs’ relief – property development and investment company – whether ‘trading company’ – s165A(3) TCGA 1992 – no – appeal dismissed INCOME TAX – transactions in securities – whether main purpose or one of the main purposes of person being a party was to obtain an income tax advantage – s684(1)(c) ITA 2007 – no – appeal allowed INCOME TAX – remittance basis – business investment relief – whether unpaid or reinvested dividends treated as an investment -whether payment of unpaid or reinvested dividends was a ‘potentially chargeable event’ – s809VG ITA 2007 – appeal dismissed
[2020] UKFTT 216 (TC)
Bailii
England and Wales
Updated: 17 September 2021; Ref: scu.651593 br>