Hawksbridge Llp v Revenue and Customs: FTTTx 7 May 2014

FTTTx INCOME TAX – loss relief – arrangements for exploitation of intellectual property rights – whether first-year losses incurred – whether large part of money used for exploitation of rights or for purchase of guaranteed income stream – guaranteed income stream – whether remainder used within first accounting period and allowable loss in that year – whether capital or income payments – Icebreaker 1 considered – arrangements essentially a tax avoidance scheme – appeals against closure notices substantially dismissed
REFERENCE – TMA s 28ZA – whether partnerships’ trade commercial – no – whether members non-active – yes – whether Restrictions Regulations apply – no, as none of conditions satisfied – whether ITA s 74ZA applies to later iteration – yes

Judges:

Bishopp TJ

Citations:

[2014] UKFTT 416 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Taxes Management, Income Tax

Updated: 05 June 2022; Ref: scu.525400