Income Tax/Corporation Tax : Profits – connected parties – sale of property below market value – assessments appealed – valuation being the only ground of appeal – matter referred to Lands Tribunal – agreement on valuation before hearing – whether Consent Order on valuation can be characterised as a s 54 TMA agreement; yes – (a) common intention to reach agreement over a particular matter; (b) agreement in relation to the assessments under appeal; (c) agreement competent to fix quantum of assessments and to dispose of substantive matter under appeal – settlement of appeals ensued within the statutory context of – ‘like consequences’ – A’s application to amend grounds of appeal refused
Citations:
[2018] UKFTT 293 (TC)
Links:
Jurisdiction:
England and Wales
Corporation Tax
Updated: 25 April 2022; Ref: scu.619364