FTTTx Corporation tax – receipts of payments in respect of overpaid VAT and statutory interest – whether VAT repayments trading receipts – whether payments in respect of supplies made in discontinued trades chargeable to tax as post-cessation receipts – ICTA 1988, ss 103 and 106(2) – whether payments in respect of interest taxable under Sch D, Case III – loan relationships rules – whether a ‘money debt’ – FA 1996, s 100
Roger Berner J
[2012] UKFTT 127 (TC)
Bailii
Income and Corporation Taxes Act 1988 103 106
England and Wales
Cited by:
Appeal from – Shop Direct Group, Littlewoods Retail Ltd and Others v HMRC UTTC 19-Apr-2013
UTTC Corporation Tax: Effect of receipt by trader or successor to trade of sums in respect of VAT repaid under s80 VATA to representative member of VAT group plus interest paid under s78 VATA. Question of . .
At FTTTx – Shop Direct Group and Others v HM Revenue and Customs ChD 19-Apr-2013
. .
At FTTTx – Shop Direct Group v Revenue and Customs CA 11-Mar-2014
The company sought to challenge the assessment to corporation tax of a very large repayment of VAT, together with an even larger amount of interest.
Held: The appeal failed. . .
At FTTTx – Shop Direct Group v Revenue and Customs SC 17-Feb-2016
The Court considered the interpretation of the sections which applied corporation tax to post-cessation receipts. Companies had received from the Inland Revenue substantial repayments of VAT together with interest. There had been reorganisations of . .
Lists of cited by and citing cases may be incomplete.
Corporation Tax
Updated: 11 November 2021; Ref: scu.451988