Odey Asset Management Llp v Revenue and Customs (Income Tax – Tax Effects of A Partnership Incentive Plan): FTTTx 4 Feb 2021

INCOME TAX – tax effects of a partnership incentive plan – whether the appellants are taxable on sums allocated to a corporate member of Odey Asset Management LLP in the year of allocation – no – whether the appellants are taxable on sums received on reallocation of special capital to them in the year of receipt under s 687 ITTOIA 2005 (miscellaneous income) – yes – or under ss 773 to 778 ITA 2007 (sales of occupational income) – no – whether an amendment and various discovery amendments were made validly under s 29 and 30B TMA – appeal allowed in part

Citations:

[2021] UKFTT 31 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Income Tax

Updated: 09 December 2022; Ref: scu.661768