Category: Income Tax

Commission v Belgium – C-110/17: ECJ 12 Apr 2018

Free Movement of Capital – Tax On The Income of Belgian Residents – Judgment – Failure of a Member State to fulfil obligations – Free movement of capital – Article 63 TFEU – Article 40 of the EEA Agreement – Tax on the income of Belgian residents – Calculation of income from immovable property – Application of two different calculation methods depending on the place in which the immovable property is situated – Calculation on the basis of the cadastral value for immovable property located in Belgium – Calculation based on the actual rental value for immovable property located in another Member State of the European Union or the European Economic Area (EEA) – Difference in treatment – Restriction on the free movement of capital

Citations:

C-110/17, [2018] EUECJ C-110/17

Links:

Bailii

Jurisdiction:

European

Income Tax

Updated: 07 April 2022; Ref: scu.608631

Revenue and Customs v West: UTTC 29 Mar 2018

Income Tax and National Insurance Contributions (NICS) calculation of gross remuneration in an amount which, after deduction of PAYE and NICs, would equal and extinguish liability of director to company on director’s loan account – company insolvent and unable to pay tax and NICs – whether tax deducted by company – whether director received relevant payments knowing that the company had wilfully failed to deduct PAYE – regulation 72, Income Tax (Pay As You Earn) Regulations 2003 – whether company failed to deduct and pay primary NICs and the director knew that the company had wilfully failed to pay – regulation 86, Social Security (Contributions) Regulations 2001.

Citations:

[2018] UKUT 100 (TCC)

Links:

Bailii

Jurisdiction:

England and Wales

Taxes – Other, Income Tax

Updated: 07 April 2022; Ref: scu.608588

The National Provident Institution v Brown (Surveyor of Taxes): HL 3 Jun 1921

The House was asked (inter alia) whether discounts on certain Treasury Bills could be subject to taxation, on a preceding year basis, for a year in which the taxpayer did not hold or have any transactions in the relevant securities.
Held: The appeal failed (by a majority) Tax could not be charged on that basis. The tax was intended as a matter of basic principle to be on profits and gains forming income in the year of assessment, though measured by the income, not of that year, but of the preceding year.
Viscount Haldane approved a dictum in the CA, saying: ‘the general principle of the Acts is to make the tax apply only to a source of income existing in the year of assessment’.
Lord Sumner emphasised the width of the statutory language: ‘The rule . . relates to ‘profits’ on all discounts from whomsoever made. There is no definition of discount in the statutes; no restriction of it to transactions in use in the year 1842; no evidence of its meaning as a term of art at any time’
Lord Atkinson considered the language of the statute: ‘The words are not happily chosen, but must, I think, be taken to mean ‘all profits arising from discount”.
Viscount Cave emphasised that a purchase, of a Treasury bill from the Treasury, was a transaction by way of discount, and, if it were decided otherwise, ‘an easy way would be opened to money lenders of evading the payment of tax on their interest on short loans’. The legislation invited no investigation on what accretion was capital and what was income; the whole profit was to be treated as an income profit. A relevant factor of importance was that the amount secured by the bill remained unaltered.

Judges:

Viscount Haldane, Lord Sumner, Lord Atkinson, Viscount Cave

Citations:

[1921] UKHL TC – 8 – 57, [1921] 2 AC 222, 8 TC 57

Links:

WLRD

Statutes:

Income Tax 1842

Jurisdiction:

England and Wales

Citing:

Appeal from – The National Provident Institution v Brown (Surveyor of Taxes) CA 10-May-1920
Lord Sterndale MR said: ‘It seems to me to be a general principle of Income Tax Law that a person in order to be taxable in a particular year must have an income arising from a source existing in that year and in order to justify this assessment the . .

Cited by:

Cited – Shop Direct Group v Revenue and Customs CA 11-Mar-2014
The company sought to challenge the assessment to corporation tax of a very large repayment of VAT, together with an even larger amount of interest.
Held: The appeal failed. . .
Cited – Shop Direct Group v Revenue and Customs SC 17-Feb-2016
The Court considered the interpretation of the sections which applied corporation tax to post-cessation receipts. Companies had received from the Inland Revenue substantial repayments of VAT together with interest. There had been reorganisations of . .
Lists of cited by and citing cases may be incomplete.

Income Tax

Updated: 06 April 2022; Ref: scu.606459

Wood v Revenue and Customs: FTTTx 13 Feb 2018

Income Tax/Corporation Tax : Penalty – individual tax return – penalties for late filing – whether giving notice under Section 8(1) TMA a pre-requisite for filing a tax return under Section 8(1)(a) – yes – if no such notice given can Schedule 55 apply – no – on the facts no notice given – appeal allowed.

Citations:

[2018] UKFTT 74 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 05 April 2022; Ref: scu.605755

Saheid v Revenue and Customs (Income Tax/Corporation Tax : Appeal): FTTTx 23 Mar 2016

INCOME TAX – HMRC amendments relating to disallowance of loan interest and legal costs upheld – whether legal costs eligible for post cessation trade relief -no – appeal in relation to 2005-6 dismissed – whether s54 TMA 1970 agreement for other earlier years as argued for by HMRC – no – lack of written notice of appeal to HMRC meant no s54 agreement but also meant no valid appeal before tribunal for earlier years- proceedings in relation to 2001-2 to 2004-5 proposed to be struck out for lack of jurisdiction.

Citations:

[2016] UKFTT 224 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 05 April 2022; Ref: scu.561923

Shah v Revenue and Customs: FTTTx 6 May 2014

INCOME TAX – relief for losses – whether taxpayer conducting a self-employed occupation as a reinsurance and business consultant – whether expenditure incurred wholly and exclusively for the purposes of that occupation – appeal dismissed

Citations:

[2014] UKFTT 432 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 05 April 2022; Ref: scu.526877

Cyclops Electronics Ltd and Graceland Fixing Ltd v Revenue and Customs: UTTC 17 Jan 2018

Income Tax, National Insurance Contributions – award of bonuses in the form of loan notes – whether those loan notes were restricted securities for the purposes of Part 7 ITEPA – whether employees to be treated as receiving cash.

Citations:

[2018] UKUT 7 (TCC)

Links:

Bailii

Jurisdiction:

England and Wales

Taxes – Other, Income Tax

Updated: 04 April 2022; Ref: scu.604783

Higgins v National Crime Agency: UTTC 16 Jan 2018

UTTC INCOME TAX -‘income tax assessments’ – ‘best judgment’ – confiscation order – proceeds of crime – agreed basis of plea – tax liability – assessment stage – enforcement stage – double recovery – double jeopardy.

Citations:

[2018] UKUT 14 (TCC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 04 April 2022; Ref: scu.604784

Christianuyi Ltd and Others v Revenue and Customs: UTTC 19 Jan 2018

UTTC INCOME TAX – whether appellants were ‘managed service companies’ – s.61B(2) Income Tax (Earnings and Pensions) Act 2003 (‘ITEPA’) – whether a managed service company provider was ‘involved’ with the appellants – whether the provider ‘benefits financially’ from the provision of services – the meaning of ‘influences or controls’.

Citations:

[2018] UKUT 10 (TCC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 04 April 2022; Ref: scu.604782

Vaines v HM Revenue and Customs: CA 25 Jan 2018

Appeal by the taxpayer from a decision of the Upper Tribunal allowing the appeal of the Commissioners from the decision of the First-tier Tribunal uphelding a claim by Mr Vaines to be entitled to deduct a sum from his share of the profits of his profession as a solicitor in the tax year 2007/08.

Citations:

[2018] EWCA Civ 45

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 04 April 2022; Ref: scu.604154

Halfaoui v Revenue and Customs (Income Tax/Corporation Tax : Penalty): FTTTx 8 Jan 2018

INCOME TAX – late filing daily penalty – HMRC witness statement provided in the course of the hearing – generic evidence – whether to admit witness statement into evidence – whether HMRC met the burden of proof – appeal allowed

Citations:

[2018] UKFTT 13 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 03 April 2022; Ref: scu.602933

School Estates Consultancy Ltd v Revenue and Customs (Income Tax/Corporation Tax : Employment Income): FTTTx 29 Dec 2017

FTTTx INCOME TAX, NATIONAL INSURANCE CONTRIBUTIONS (NICs) AND VAT – security for payment of income tax, NICs and VAT -reasonableness of decisions that security required – application of appellate jurisdiction in relation to notice requiring security for PAYE and NICs – appeals dismissed

Citations:

[2018] UKFTT 4 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 03 April 2022; Ref: scu.602930

Goldsmith v Revenue and Customs (Income Tax/Corporation Tax : Penalty): FTTTx 3 Jan 2018

FTTTx INCOME TAX – penalties for failure to file returns for 2 years – appellant would not or could not pay underpayment shown on P800s and said by HMRC not to be capable of being coded out – notice to file returns given to establish enforceable debt arising from self-assessment – whether Tribunal has jurisdiction to take into account whether returns issued for purpose in s 8(1) TMA – PML and Birkett considered – held penalties invalid as not issued for s 8(1) purpose – in alternative whether reasonable excuse for failure to file on time: held no – in alternative whether HMRC decision on special circumstances flawed: held yes – there were unusual or out of the ordinary circumstances that justified reduction in penalties, and that the imposition of the penalties was not in accordance with the clear compliance intention of the legislation – penalties cancelled.

Citations:

[2018] UKFTT 5 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 03 April 2022; Ref: scu.602932

Hammon v Revenue and Customs (Income Tax – Penalties for Failure To Make Return On Time): FTTTx 16 Oct 2020

INCOME TAX – penalties for failure to make return on time – appellant had moved to France over a year before tax return became due, and had a baby a month after it became due – she then had little support in taking care of the baby – no reasonable excuse for failing to file the return until more than six months after due date, as reasonably conscientious taxpayer in her situation would have done so prior to filing date – not right to reduce penalties due to special circumstances – appeal dismissed

Citations:

[2020] UKFTT 412 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 03 April 2022; Ref: scu.655329

Taylor v Revenue and Customs (Income Tax – Allowable Expenses – Closure Notice): FTTTx 17 Oct 2020

INCOME TAX – ALLOWABLE EXPENSES – Closure Notice – Penalty -Subcontractor staying away from home for 165 days – business base – Section 34 Income Tax (Trading and Other Income) Act 2005 ‘Wholly and exclusively’ – appeal against Closure Notice dismissed – appeal against Penalty Notice allowed.

Citations:

[2020] UKFTT 416 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 03 April 2022; Ref: scu.655352

Pirasana v Revenue and Customs (Income Tax : Fixed and Daily Penalties for Failure To File A Self-Assessment Return On Time): FTTTx 17 Aug 2020

INCOME TAX – Schedule 55 Finance Act 2009 – fixed and daily penalties for failure to file a self-assessment return on time – mental illness and personal problems – whether taxpayer had a reasonable excuse for his default – appeal allowed in part.

Citations:

[2020] UKFTT 334 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 03 April 2022; Ref: scu.654095

Oceanic Creations London Ltd v Revenue and Customs (Income Tax – Fixed Penalty for Failure To File): FTTTx 24 Aug 2020

INCOME TAX – Schedule 55 Finance Act 2009 – fixed penalty for failure to file an Employer Real Time Information (RTI) return on time – whether taxpayer had a reasonable excuse for his default – appeal dismissed. Application for leave to appeal out of time – dismissed.

Citations:

[2020] UKFTT 341 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 03 April 2022; Ref: scu.654093

HM Revenue and Customs v Barclays Bank Plc and Another: ChD 11 Aug 2006

The bank had made payments to former employees to recompense them for the termination of a free service under which they had received tax advice.
Held: The payment was made in connection with past services as employees, and was chargeable to income tax.

Judges:

David Richards J

Citations:

[2006] EWHC 2118 (Ch), Times 12-Sep-2006

Links:

Bailii

Statutes:

Income Tax (Employment) Regulations 1993

Jurisdiction:

England and Wales

Income Tax

Updated: 03 April 2022; Ref: scu.244232

Wallace v Revenue and Customs: ChD 6 Dec 2017

The court was asked whether the relevant statutory regime permitted the claimant to pursue a claim at common law for restitution of overpaid income tax or, whether the court has jurisdiction to entertain the claim.
Held: They are two sides of the same coin. The court has no jurisdiction to entertain this claim and, therefore, the claimant has no reasonable grounds for bringing it.

Judges:

Marsh CM

Citations:

[2017] EWHC 3115 (Ch)

Links:

Bailii

Jurisdiction:

England and Wales

Citing:

Appeal from – Wallace v Revenue and Customs FTTTx 12-Apr-2013
Procedure – dismissed out of time . .
Lists of cited by and citing cases may be incomplete.

Taxes Management, Income Tax

Updated: 02 April 2022; Ref: scu.601840

Cooke v Revenue and Customs: FTTTx 24 Nov 2017

FTTTx Income Tax/Corporation Tax : Assessment/Self-Assessment – INCOME TAX – discovery assessment – excessive claim to double tax relief – error could be determined from information in return – whether HMRC officer could not have reasonably be expected to be aware so that s 29(5) satisfied – whether appellant’s representative careless so that s 29(4) satisfied – appeal allowed

Citations:

[2017] UKFTT 844 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 02 April 2022; Ref: scu.600946

Stanley v Revenue and Customs: FTTTx 20 Oct 2017

FTTTx Income Tax/Corporation Tax : Penalty – Sch 24 FA 2007 penalty – (1) whether SA return inaccurate by inclusion of share loss relief claims under s 131 ITA 2007 – (a) time-bar issue, whether condition precedent met with an effective claim under s 24 TCGA – (b) formality issue, whether s 42(2) of TMA prevails – Sch 1A and Sch 1B to TMA – Rouse, Cotter, Derry and De Silva considered – (2) whether inaccuracy ‘deliberate’ or ‘careless’ on the taxpayer’s part – (3) whether reasonable care taken to avoid inaccuracy – para 18 Sch 24 on ‘agency’ – appeal allowed in part

Citations:

[2017] UKFTT 793 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 02 April 2022; Ref: scu.600935

Spink v Revenue and Customs: FTTTx 28 May 2014

Schedule 56 Finance Act 2009 – penalties for late payment of tax – Appellant advised by DWP that lump sum pension payment had been paid to her ‘net of tax’ which was subsequently discovered to be incorrect – whether reasonable excuse – yes – appeal allowed

Citations:

[2014] UKFTT 524 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 01 April 2022; Ref: scu.526881

Gratton v Revenue and Customs: FTTTx 28 Oct 2010

Income Tax – Schedule E – S.647 FCTA 1988 – Pension Fund Transfer – Unauthorised – Yes – Reciprocal Arrangements for Transfer between UK and Guernsey – Appellant liable for income tax – Not liable to penalties and interest – Appeal dismissed

Citations:

[2010] UKFTT 521 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 01 April 2022; Ref: scu.426620

Jama v Revenue and Customs (Income Tax : Fixed and Daily Penalties for Failure To File A Self-Assessment): FTTTx 17 Aug 2020

INCOME TAX – Schedule 55 and 56 Finance Act 2009 – fixed and daily penalties for failure to file a self-assessment return on time – penalties for late payment – whether taxpayer had a reasonable excuse for his default – appeal allowed in part. Permission to appeal out of time – granted.

Citations:

[2020] UKFTT 336 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 01 April 2022; Ref: scu.654089

Morris v Revenue and Customs: FTTTx 11 Sep 2017

Income Tax/Corporation Tax : Penalty – Income tax – Schedule 55 Finance Act 2009 – fixed penalties for late filing of self-assessment returns – Appellant had ceased self-employment but had not notified HMRC – whether reasonable excuse – no – appeal dismissed

Citations:

[2017] UKFTT 685 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 01 April 2022; Ref: scu.598983

Klein v Revenue and Customs: FTTTx 12 Sep 2017

Income Tax/Corporation Tax : Penalty – INCOME TAX – penalties for failure to file returns – Schedule 55 FA 2009 – whether failure to make return by due dates: yes – whether penalties properly imposed: yes, except daily penalties – Donaldson followed – whether reasonable excuse for failure: yes in relation to initial penalty, no for others as excuses ceased – whether special circumstances – yes: HMRC decision flawed – 6 month penalty reduced to pounds 100.

Citations:

[2017] UKFTT 689 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 01 April 2022; Ref: scu.598978

O’Neill v Revenue and Customs: FTTTx 12 Sep 2017

Income Tax/Corporation Tax : Penalty – Income tax – Schedule 55 Para 23 of the Finance Act 2009 – fixed and daily penalties for late filing of self-assessment return – Appellant suffering from illness and depression causing initial delay – agent later added to delay by overlooking to file return despite reminders from Appellant – whether reasonable excuse – on the facts – yes – appeal allowed

Citations:

[2017] UKFTT 688 (TC)

Links:

Bailii

Statutes:

Finance Act 2009

Jurisdiction:

England and Wales

Income Tax

Updated: 01 April 2022; Ref: scu.598984

Merrie v Revenue and Customs: FTTTx 11 Sep 2017

Income Tax/Corporation Tax : Penalty – Penalty Income tax – FA 2007 Sch 24 – inaccuracy in tax return – Capital Gain not disclosed – whether inaccuracy was careless and prompted – yes – Sch 24 para 14 – whether penalty should have been suspended – no – Appeal dismissed

Citations:

[2017] UKFTT 684 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 01 April 2022; Ref: scu.598981

Berthet v Revenue and Customs: FTTTx 14 Sep 2017

Income Tax/Corporation Tax : Penalty – Income tax – Schedule 55 Finance Act 2009 – daily penalty for late filing of self-assessment return – Appellant had prematurely and erroneously registered with HMRC for self-assessment – Notice to File issued – s8A TMA 1970 – special circumstances – Sch 55 para 16 – Appellant unaware and not advised that HMRC may withdraw a Notice to File – HMRC’s internal guidance SAM120000 considered – whether special circumstances – yes – Sch 55 Para 17A – cancellation of penalties – appeal allowed and penalty cancelled

Citations:

[2017] UKFTT 694 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 01 April 2022; Ref: scu.598975

Sankey v Revenue and Customs (Income Tax/Corporation Tax : Penalty): FTTTx 10 Oct 2017

INCOME TAX – penalty for failure to make return timeously -HMRC’s burden of proof when daily penalties charged-appeal against daily penalties allowed-appeal against pounds 100 and pounds 300 penalties dismissed

Citations:

[2017] UKFTT 747 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 01 April 2022; Ref: scu.598802

Baloch v Revenue and Customs: FTTTx 5 Sep 2017

Income Tax/Corporation Tax – INCOME TAX – doctor providing locum services via agency – whether income earned by self-employed individual or company – whether income tax or corporation tax chargeable – whether HMRC were entitled to make a discovery assessment – time limits: whether the taxpayer was careless-whether penalties were properly charged on the basis of deliberate inaccuracies in tax return.

Citations:

[2017] UKFTT 665 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 30 March 2022; Ref: scu.595443

Craft v Revenue and Customs (Income Tax – High Income Child Benefit Charge): FTTTx 21 Oct 2020

INCOME TAX – High income child benefit charge (HICBC) – discovery assessment under s 29 of TMA – penalty for failure to notify liability – Schedule 41 to Finance Act 2008 – appellant unaware of the obligation to notify – whether reasonable excuse – on the facts – no – appeal refused

Citations:

[2020] UKFTT 420 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 30 March 2022; Ref: scu.655325

Beer v Revenue and Customs: FTTTx 1 Sep 2017

Income Tax/Corporation Tax : Penalty – INCOME TAX – penalty for failure to make returns – did appellant have a reasonable excuse for the failure? – No – jurisdiction of Tribunal to consider whether late filing penalties under schedule 55 Finance Act 2009 are unfair or disproportionate – s 6 Human Rights Act 1998 – article 1 of the First Protocol to the European Convention on Human Rights – appeal dismissed

Citations:

[2017] UKFTT 662 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax, Human Rights

Updated: 30 March 2022; Ref: scu.594557

Payne, Garbett, Coca-Cola European Partners Breat Britain Ltd v Revenue and Customs: FTTTx 30 Aug 2017

FTTTX Income Tax/Corporation Tax : Employment Income – INCOME TAX – ITEPA 2003 Part 3 Chapter 6 – provision of cars, vans and fuel to employees – whether three vehicles were ‘goods vehicles’ – whether ‘a vehicle of a construction primarily suited to the conveyance of goods or burden’ within s 115(2) ITEPA 2003-modifications to vehicles – correct test to be applied

Citations:

[2017] UKFTT 655 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 30 March 2022; Ref: scu.594552

Joshi v Revenue and Customs: FTTTx 16 Aug 2017

(Income Tax/Corporation Tax : Penalty) – Income tax – fixed penalties for late filing of self-assessment returns – Appellant was a director of newly formed company and unaware of obligation to file individual returns – whether reasonable excuse – no – appeal dismissed

Citations:

[2017] UKFTT 644 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 30 March 2022; Ref: scu.594549

Chadwick (As Trustee In Bankruptcy of Oduneye-Braniffe) v The National Crime Agency: FTTTx 30 Aug 2017

Income Tax/Corporation Tax : Proceeds of Crime Act – INCOME TAX – Exercise of revenue functions by NCA – whether qualifying condition met – validity of assessments on pre-bankruptcy income addressed to trustee – whether deliberate conduct properly pleaded – validity of assessments assessing one figure on two bases – whether returns required and made – whether discovery of loss of tax – whether bankrupt was carrying on trade of money laundering from which profits arose – appeals allowed.

Citations:

[2017] UKFTT 656 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax, Taxes Management

Updated: 30 March 2022; Ref: scu.594543

Madonna Halley’s Hotel v Revenue and Customs: FTTTx 29 Aug 2017

(Income Tax/Corporation Tax : Penalty) – INCOME TAX – penalty for delay in filing return – delay by taxpayer in filing appeal to HMRC against penalty – HMRC refuse to admit appeal out of time – application to Tribunal under Section 49 Taxes Management Act 1970 for appeal to HMRC to be admitted out of time

Citations:

[2017] UKFTT 652 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 30 March 2022; Ref: scu.594550

Bells v Revenue and Customs (Income Tax – Application To Strike Out Appeal): FTTTx 20 Aug 2020

Income Tax – application to strike out appeal on basis that no appealable decision – incorrect tax deducted under PAYE – assessments raised on basis of self-assessment tax returns – underpayments for 2009-10 and 2012-13 – no disagreement as to tax liability – whether or not taxpayer can appeal against own self-assessment – held not – whether or not tribunal can consider application of PAYE regulations – held not – no appealable decision – appeal struck out

Citations:

[2020] UKFTT 340 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 28 March 2022; Ref: scu.654082