FTTTX INCOME TAX – Loss relief – Qualifying trading company – Appellants’ shares in ‘start-up’ company carrying on business in UK – Shares exchanged for shares in Canadian company – Canadian company shares disposed of at loss – Whether loss relief available against income – ICTA 1988 s.574
ENQUIRY – Enquiry into availability of loss relief – Enquiry started on basis that loss relief was denied on account of co-ownership of shares – Later HMRC realised that a different condition for relief was not fulfilled – Whether that started a new enquiry – No – TMA 1970 s.9A
[2010] UKFTT 560 (TC)
Bailii
England and Wales
Income Tax, Taxes Management
Updated: 20 January 2022; Ref: scu.567555