Income Tax – Charity – whether or not loan to company was an approved charitable investment – whether loan for the benefit of the charity and not for the avoidance of tax – determination of amount of non-allowable expenditure – whether or not FTT has full appellate jurisdiction or merely supervisory jurisdiction – held that loan was for the benefit of the charity but also for the avoidance of tax – held that the amount of non-allowable expenditure should be determined by reference to payments made in tax year – held that FTT’s jurisdiction was merely supervisory as regards HMRC’s decision but that HMRC’s decision was not unreasonable in principle but had determined the amount of non-allowable expenditure wrongly – appeal allowed in part
[2020] UKFTT 303 (TC)
Bailii
England and Wales
Income Tax, Charity
Updated: 27 December 2021; Ref: scu.653144