INCOME TAX /CORPORATION TAX – Losses – interpretation of s118ZC ICTA 1988 limit on loss relief for members of LLPs- test for admissibility of extra-statutory materials not met – whether appellant’s third share in capital of LLP was ‘contributed’ as capital (s118ZC(3) ICTA) on basis that this was the amount appellant had exposed to risk- no – whether appellant’s third share was included in amount the appellant was ‘liable to contribute’ to the assets of the LLP in the event LLP was wound up (s118Z(4)(a) ICTA) – yes – appeal allowed
Citations:
[2014] UKFTT 350 (TC)
Links:
Jurisdiction:
England and Wales
Corporation Tax
Updated: 04 October 2022; Ref: scu.525346
