Looney; Kieran Looney and Associates (A Firm) v Revenue and Customs:: UTTC 22 Apr 2020

Tax treatment of certain payments under management training contract – whether FTT erred in conclusion termination payment trading revenue receipt (consideration for cancellation of the contract to provide training) rather than capital (compensation for loss of a secret process in proprietary performance management system) – House of Lords’ decision in Evans Medical Supplies Ltd v Moriarty (H M Inspector of Taxes) ([1957] 37 TC 540) considered – no – whether FTT erred in conclusion other contractual payments gave rise to tax liability on appellant (as opposed, through a multiparty agreement, to other entities appellant owned) – no – appeal dismissed

Citations:

[2020] UKUT 119 (TCC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 04 December 2022; Ref: scu.651190