References: [2015] UKUT 130 (TCC), [2015] BTC 512, [2015] STC 1852
Links: Bailii
Ratio:INCOME TAX /CORPORATION TAX – Losses – interpretation of s118ZC ICTA 1988 limit on loss relief for members of LLPs – whether appellant’s third share in capital of LLP was ‘contributed’ as capital (s118ZC(3) ICTA) on basis that this was the amount appellant had exposed to risk- no – whether appellant’s third share was included in amount the appellant was ‘liable to contribute’ to the assets of the LLP in the event LLP was wound up (s118Z(4)(a) ICTA) – no – appeal from Tax Chamber allowed
Last Update: 11-Jul-16
Ref: 549079