Allam v Revenue and Customs: UTTC 23 Nov 2021

PROCEDURE – automated notices requiring returns – effect of s103 Finance Act 2020 – effect of s12D TMA 1970 – validity of notices of enquiry under s9A TMA 1970 CAPITAL GAINS TAX – entrepreneurs’ relief – s165A(3) TCGA 1992 – company involved in property development and investment property – nature and extent of activities – whether a trading company INCOME TAX – remittance basis – business investment relief – whether dividend left outstanding on loan account correctly treated as an investment 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

Citations:

[2021] UKUT 291 (TCC)

Links:

Bailii

Jurisdiction:

England and Wales

Capital Gains Tax, Income Tax

Updated: 31 January 2022; Ref: scu.671209