Request for postponement of tax payment constituted claim for repayment.

Citations:

Times 02-Jun-1995

Jurisdiction:

England and Wales

Corporation Tax

Updated: 21 January 2023; Ref: scu.89027

To change a company’s accounting period, must be uncertain to Inspector. It is not an objective test.

Citations:

Ind Summary 19-Jun-1995

Statutes:

Income and Corporation Taxes Act 1988 12-8

Jurisdiction:

England and Wales

Corporation Tax

Updated: 21 January 2023; Ref: scu.82719

Income Tax/Corporation Tax : Employment Income

Citations:

[2017] UKFTT 585 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 09 December 2022; Ref: scu.592625

Application by the defendants (‘HMRC’) to make certain re-amendments to their defence to which the claimants have not consented.

Judges:

Henderson J

Citations:

[2013] EWHC 3757 (Ch)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 26 November 2022; Ref: scu.518500

The company hired out cars, receiving advance payments. Such payments in respect of future accounting periods were brought forward as accruals. On the company’s sale the company was relieved of its obligations, but kept the accruals, and were charged to corporation tax on them as profits. For tax purposes the character of a payment was not necessarily judged once and for all when received. The accruals were properly treated as trade income for the period after the sale.

Citations:

Gazette 24-Feb-2000, Times 15-Mar-2000

Statutes:

Income and Corporation Taxes Act 1988 18(1)(a)(ii)

Jurisdiction:

England and Wales

Corporation Tax

Updated: 22 November 2022; Ref: scu.89708

Section 790 of the 1988 Act should be construed to accord with European law so far as necessary to allow for the grant of tax credits for foreign dividends.

Judges:

Henderson J

Citations:

[2013] EWHC 3249 (Ch), [2013] WLR(D) 411, [2013] BTC 751, [2014] 2 CMLR 10, [2014] STC 1236, [2013] STI 3391

Links:

Bailii, WLRD

Statutes:

Income and Corporation Taxes Act 1988 790

Jurisdiction:

England and Wales

Corporation Tax

Updated: 20 November 2022; Ref: scu.516970

FTTTx CORPORATION TAX – loan relationships – debit under paragraph 19A, Schedule 9, Finance Act 1996 in respect of the difference in the accounting value of loan relationships on a change of accounting practice – appellant company changing accounting practice from UK GAAP to IFRS at the 2004 year-end – appellant claiming the debit in the 2005 accounting period – whether there was as a matter of fact the relevant difference in the accounting value – expert evidence as to UK GAAP and IFRS considered – found that there was the relevant difference in accounting value – whether in that case the debit was not to be brought into account, as being attributable to an unallowable purpose, under paragraph 13, Schedule 9, Finance Act 1996 – found that the appellant’s tax avoidance purpose was achieved at the 2004 year-end – there were no times during the 2005 accounting period during which the appellant had an unallowable purpose such that on a just and reasonable apportionment any part of the debit was to be attributed to it – appeal allowed

Citations:

[2013] UKFTT 212 (TC)

Links:

Bailii

Statutes:

Finance Act 1996

Jurisdiction:

England and Wales

Cited by:

Appeal From – Fidex Limited v Revenue and Customs UTTC 13-Nov-2014
Procedure – appeal against closure notice – reliance on grounds for amendment not stated in closure notice – Tower McCashback considered Corporation tax – loan relationships – application of paragraph 13 Sch9 FA 1996 to debit arising under para19A . .
At FTTX – Fidex Ltd v HM Revenue and Customs CA 21-Apr-2016
‘This appeal is concerned with a tax avoidance scheme called Project Zephyr. The object of this scheme was to create a loss of around 84 million Euros in the hands of the appellant (‘Fidex’) which would be available for group relief throughout the . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 17 November 2022; Ref: scu.472799

CORPORATION TAX – loans to participators – loan proving to be irrecoverable – removal of company property – deductibility – s419 ICTA 1988

Citations:

[2012] UKFTT 679 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 09 November 2022; Ref: scu.466225

Corporation Tax – late filing of return – penalty – reasonable excuse – no

Citations:

[2012] UKFTT 554 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 09 November 2022; Ref: scu.466083

The court considered the application of the ‘exclusively’ test for expenditure which was sought to be set off against tax. Examining the leading modern cases, Millett LJ said: ‘the following propositions may be derived. (1) The words for the purposes of the trade mean to serve the purposes of the trade. They do not mean for the purposes of the taxpayer but for the purposes of the trade, which is a different concept. A fortiori they do not mean for the benefit of the taxpayer. (2) To ascertain whether the payment was made for the purposes of the taxpayer’s trade it is necessary to discover his object in making the payment. Save in obvious cases which speak for themselves, this involves an inquiry into the taxpayer’s subjective intentions at the time of the payment. (3) The object of the taxpayer in making the payment must be distinguished from the effect of the payment. A payment may be made exclusively for the purposes of the trade even though it also secures a private benefit. This will be the case if the securing of the private benefit was not the object of the payment but merely a consequential and incidental effect of the payment. (4) Although the taxpayer’s subjective intentions are determinative, these are not limited to the conscious motives which were in his mind at the time of the payment. Some consequences are so inevitably and inextricably involved in the payment that unless merely incidental they must be taken to be a purpose for which the payment was made. To these propositions I would add one more. The question does not involve an inquiry of the taxpayer whether he consciously intended to obtain a trade or personal advantage by the payment. The primary inquiry is to ascertain what was the particular object of the taxpayer in making the payment. Once that is ascertained, its characterisation as a trade or private purpose is in my opinion a matter for the commissioners, not for the taxpayer.’

Judges:

Millett LJ

Citations:

[1997] STC 734, [1997] EWCA Civ 1297

Jurisdiction:

England and Wales

Citing:

Cited – Mallalieu v Drummond HL 27-Jul-1983
The taxpayer was a barrister. To comply with Bar guidance on court dress, she wore, in court and in and to and from chambers black dresses, suits and shoes and white blouses. The clothing were perfectly ordinary articles suitable for everyday wear. . .
Appeal from – Vodafone Cellular Ltd v Shaw (Inspector of Taxes) ChD 8-Mar-1995
A payment buying out technology royalties was not to be allowed against Corporation Tax. The cost of buying out a right to receive a revenue share was an income payment, not a capital payment. . .
Cited – MacKinlay (Inspector of Taxes) v Arthur Young McClelland Moores and Co HL 23-Nov-1989
Expenditure does not qualify for deduction if the object of the expenditure was to serve another private purpose in addition to the business purpose for which it was purportedly incurred.
HL Income Tax – . .

Cited by:

Cited – David Robson v Eric Mitchell (HM Inspector of Taxes) ChD 8-Jul-2004
The taxpayer sought capital gains tax relief of a loan to a business.
Held: To succeed in his claim the taxpayer had to establish that the indebtedness created was to be used entirely to serve the borrower’s business. . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 06 November 2022; Ref: scu.141693

A transfer pricing direction allowed the Inland Revenue to issue adjustments after 6 years.

Citations:

Ind Summary 08-Jan-1996, [1996] STC 191

Jurisdiction:

England and Wales

Citing:

Appeal from – Glaxo Group Ltd and Others v Inland Revenue Commissioners ChD 21-Nov-1995
A tax adjustment can be made by the Inland Revenue on an open assessment following transfer pricing enquiry and direction, even after many years. The court considered that the jurisdiction of the special and the general commissioners to determine . .

Cited by:

Cited – UK Tradecorp Ltd, Regina (on the Application of) v Commissioners for Customs and Excise Admn 10-Nov-2004
The trader had traded in zero-rated goods, leading to a net reclaim of input tax. Having submitted a claim, it sought repayment, and interest on the sums withheld.
Held: No duty fell upon the commissioners until they had accepted the claim to . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 27 October 2022; Ref: scu.80862

Capital allowances were not available on plant which had been leased to the Local Authority and which had since had become part of land occupied by them. The plant was no longer owned by the tax payers. Leased fixtures given capital allowances by sch 17 of 1985 Act after 1984.

Citations:

Gazette 19-Oct-1994, Times 17-Aug-1994, Ind Summary 05-Sep-1994

Statutes:

Finance Act 1985

Jurisdiction:

England and Wales

Citing:

Appeal from – Melluish (Inspector of Taxes) v BMI (No3) Ltd and Related Appeals ChD 15-Feb-1994
No capital allowances were available for a lease of heating equipment in a tenanted property. Allowances might be available if the property were not tenanted. . .

Cited by:

Appeal from – Melluish (Inspector of Taxes) v BMI (No 3) Ltd and Related Appeals HL 16-Oct-1995
Chattels which became affixed to a lessee’s land became fixtures, and were not available for tax allowances calculations. Lord Browne-Wilkinson said: ‘The terms expressly or implicitly agreed between the fixer of the chattel and the owner of the . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 26 October 2022; Ref: scu.83608

Group tax relief was available despite other subsidiary companies within the same group being offshore.

Citations:

Gazette 20-Oct-1993, Times 11-Aug-1993, Ind Summary 09-Aug-1993

Jurisdiction:

England and Wales

Cited by:

Appeal from – ICI Plc v Colmer (Inspector of Taxes) HL 15-Mar-1996
A ‘Holding company’ under the Act meant a company resident in the UK; A reference was made of the issues to the European Court. . .
At Court of Appeal – Imperial Chemical Industries v Colmer ECJ 16-Jul-1998
A member state was not allowed to impose a tax regime which discriminated against the subsidiaries of a company based in that state where they were based in other member states, but discrimination was allowed where the subsidiaries were based . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 26 October 2022; Ref: scu.81606

(State Aid) Appeal – Aid granted by the Italian authorities to newly listed companies – Legislation providing for tax advantages

Citations:

C-458/09, [2011] EUECJ C-458/09

Links:

Bailii

Jurisdiction:

European

Corporation Tax

Updated: 29 September 2022; Ref: scu.449366

PROFITS – capital or revenue expenditure – costs of planning inquiry – taxpayer claiming conditions in planning permission invalid or seeking relaxation of the conditions – part capital, part revenue – remitted to the First-tier Tribunal for an apportionment

Citations:

[2011] UKUT B15 (TCC), [2011] STC 1469

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 13 September 2022; Ref: scu.440822

ECJ Taxation – Interest payments between associated companies of different Member States – Deductibility of payments when determining the basis of taxation of the company making interest payments.

Citations:

C-397/09, [2011] EUECJ C-397/09

Links:

Bailii

Jurisdiction:

European

Corporation Tax

Updated: 12 September 2022; Ref: scu.439767

Corporation tax – deductibility of payment to employee benefit trust (EBT) – whether payment made wholly and exclusively for the purpose of appellant’s trade – ICTA 1988 s 74(1)(a) – whether payment revenue or capital expenditure – ICTA, s 74(1)(f) – whether payment a ‘potential emolument’ – FA 1989, s 43(11)

Citations:

[2011] UKFTT 16 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 01 September 2022; Ref: scu.428211

Corporation Tax – Insurance company – with-profits policy holders sharing in profits of with-profits policies only-meaning of ‘separate revenue account required to be prepared’ in FA 1989 s 83A(2)(b)

Citations:

[2010] UKUT B19 (TCC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 01 September 2022; Ref: scu.428171

A tax adjustment can be made by the Inland Revenue on an open assessment following transfer pricing enquiry and direction, even after many years. The court considered that the jurisdiction of the special and the general commissioners to determine such issues was exclusive: ‘It is not easy to discern any clear dividing-line between High Court proceedings which are, and those which are not, objectionable as attempts to circumvent the exclusive jurisdiction principle. Possibly the correct view is that there is an absolute exclusion of the High Court’s jurisdiction only when the proceedings seek relief which is more or less co-extensive with adjudicating on an existing open assessment: but that the more closely the High Court proceedings approximate to that in their substantial effect, the more ready the High Court will be, as a matter of discretion, to decline jurisdiction.’

Judges:

Robert Walker J

Citations:

Times 21-Nov-1995, Ind Summary 11-Dec-1995, [1995] STC 1075

Statutes:

Income and Corporation Taxes Act 1988 770

Jurisdiction:

England and Wales

Cited by:

Appeal from – Glaxo Group Ltd v Inland Revenue Commissioners CA 8-Jan-1996
A transfer pricing direction allowed the Inland Revenue to issue adjustments after 6 years. . .
Applied – Claimants under the Loss Relief Group Litigation Order v Inland Revenue Commissioners ChD 3-Mar-2004
Various claimants sought to have issues of law on group relief and other issues settled under a group litigation order.
Held: The High Court had no jurisdiction to hear such matters until they had first been raised in ordinary tax appeals . .
Cited – UK Tradecorp Ltd, Regina (on the Application of) v Commissioners for Customs and Excise Admn 10-Nov-2004
The trader had traded in zero-rated goods, leading to a net reclaim of input tax. Having submitted a claim, it sought repayment, and interest on the sums withheld.
Held: No duty fell upon the commissioners until they had accepted the claim to . .
Approved – Autologic Holdings Plc and others v Commissioners of Inland Revenue HL 28-Jul-2005
Taxpayer companies challenged the way that the revenue restricted claims for group Corporation Tax relief for subsidiary companies in Europe. The issue was awaiting a decision of the European Court. The Revenue said that the claims now being made by . .
Applied – Capper v Chaney and Another ChD 8-Jul-2010
Police had seized substantial sums of cash from the first defendant acting under the 2004 Act. The claimant said that andpound;250,00 was his and sought its return. The Commissioner argued that the current proceedings were an abuse of process.
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 24 August 2022; Ref: scu.80861

When principal in group of companies relocated abroad, inter-group transfer of shares resulting was chargeable to corporation tax.

Citations:

Times 16-Mar-1998

Statutes:

Income and Corporation Taxes Act 1988 278

Jurisdiction:

England and Wales

Corporation Tax

Updated: 24 August 2022; Ref: scu.80172

Once a dispute on an assessment has been settled between the taxpayer and the Inspector, the taxpayer cannot subsequently appeal against refusal of relief for a claim of an error. There was no point of law in such an error.

Citations:

Times 21-May-1999

Statutes:

Taxes Management Act 1970 54 33

Jurisdiction:

England and Wales

Citing:

Appealed to – Eagerpath Ltd v Edwards (HM Inspector of Taxes) CA 14-Dec-2000
Where the special commissioner had determined that the dispute had been concluded by agreement, the taxpayer was precluded from appealing that decision claiming an ‘error or mistke’ That issue was not one relating to the computation of profits in . .

Cited by:

Appeal from – Eagerpath Ltd v Edwards (HM Inspector of Taxes) CA 14-Dec-2000
Where the special commissioner had determined that the dispute had been concluded by agreement, the taxpayer was precluded from appealing that decision claiming an ‘error or mistke’ That issue was not one relating to the computation of profits in . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 24 August 2022; Ref: scu.80205

The Court was asked whether or not certain expenditure incurred by the Appellant (‘Dawsongroup’) was deductible in computing its profits for the purposes of corporation tax

Judges:

Mann J

Citations:

[2010] EWHC 1061 (Ch), [2010] STC 1906, [2010] BTC 1528

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 18 August 2022; Ref: scu.415086

ECJ Judgment – Reference for a preliminary ruling – Articles 49 TFEU, 54 TFEU, 107 TFEU and 108(3) TFEU – Freedom of establishment – State aid – Taxation of groups of companies – Acquisition of a holding in a subsidiary – Depreciation of the goodwill – Limitation on holdings in resident companies

Citations:

ECLI:EU:C:2015:661, [2015] EUECJ C-66/14

Links:

Bailii

Jurisdiction:

European

Corporation Tax

Updated: 18 August 2022; Ref: scu.553097

Penalty – Failure to provide information and documents – reliance on accountant – Whether reasonable excuse – No – Appeal dismissed – Paragraph 29 schedule 18 Finance Act 1998

Citations:

[2009] UKFTT 329 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 17 August 2022; Ref: scu.409108

Judges:

Peter Smith J

Citations:

[2010] EWHC 609 (Ch), [2010] BTC 467, 12 ITL Rep 935, [2010] STI 1284, [2010] STC 1379

Links:

Bailii

Jurisdiction:

England and Wales

Cited by:

Appeal from – Bayfine UK v HM Revenue and Customs CA 23-Mar-2011
The revenue appealed against the confirmation of the grant of double taxation relief to the taxpayer company. The Court was asked whether the UK company was entitled under article 23(2)(a) to a credit, to set against UK tax on its profits, in . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 16 August 2022; Ref: scu.403482

The part use of an industrial building as an office defeats a capital allowance claim.

Citations:

Gazette 01-May-1996, Times 21-Mar-1996

Statutes:

Capital Allowances Act 1990 18

Jurisdiction:

England and Wales

Citing:

Appealed to – Girobank Plc v Clarke (HM Inspector of Taxes) CA 19-Dec-1997
The use of a building for data processing does not qualify it as the subjection of goods or materials to any process and therefore no capital allowance was claimable. . .

Cited by:

Appeal from – Girobank Plc v Clarke (HM Inspector of Taxes) CA 19-Dec-1997
The use of a building for data processing does not qualify it as the subjection of goods or materials to any process and therefore no capital allowance was claimable. . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 14 August 2022; Ref: scu.80844

Platforms installed for storage were plant for capital allowances.

Citations:

Gazette 02-Sep-1992

Jurisdiction:

England and Wales

Corporation Tax

Updated: 06 August 2022; Ref: scu.81528

UTTTC Corporation Tax – mistaken payments by taxpayer’s customers – whether arising or accruing from trade

Citations:

[2011] UKUT B8 (TCC), [2011] STI 739, [2011] STC 1346, [2011] BTC 1675

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 05 August 2022; Ref: scu.440814

ECJ (Taxation) Failure of a Member State to fulfill obligations) Free movement of capital Article 56 EC Articles 31 and 40 of the EEA Agreement Direct taxation Withholding tax on outgoing dividends Deduction to the registered office of the beneficiary of the dividend under a preventive double taxation

Citations:

C-540/07, [2009] EUECJ C-540/07 – O

Links:

Bailii

Jurisdiction:

European

Cited by:

Opinion – Commission v Italy C-540/07 ECJ 19-Nov-2009
ECJ Failure of a Member State to fulfil obligations Free movement of capital Article 56 EC Articles 31 and 40 of the EEA Agreement Direct taxation Withholding at source on outgoing dividends Set-off at the place . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 03 August 2022; Ref: scu.374262

FTTTx CORPORATION TAX – de-listing of quoted company – whether costs of delisting allowable expense in corporation tax computation – whether company an ‘investment company’ – ICTA s 130 – no – whether costs ‘expenses of management’ – ICTA s 75 – no – appeal dismissed

Citations:

[2009] UKFTT 137 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 03 August 2022; Ref: scu.373677

Citations:

[2009] UKFTT 141 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 30 July 2022; Ref: scu.373599

Judges:

Henderson J

Citations:

[2008] EWHC 1363 (Ch)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 17 July 2022; Ref: scu.270218

The taxpayer company had received compensation for having been excluded from its business premises for a period until a compulsory purchase process failed. It treated the receipt as capital. The revenue said it was income.
Held: The court considered how to treat mistakes of law by lower courts.
Buxton LJ said: ‘We were assured on all sides that the present issue is one of law. So be it: but it is an issue of law of a rather special sort, not least because . . . the distinction between capital and income has to be determined from a practical and business point of view. . . For my part, and whatever the technical jurisprudential position, I would think that the time has now come to leave these practical and business issues principally in the hands of the specialist tribunal that has been constituted to decide them. Parties should in future hesitate long before contending that a view taken by that specialist tribunal is apt for reconsideration by the High Court, and much less by this court.’
Lawrence Collins LJ said: ‘There is much to be said for the view, expressed in a different context, that where the answer to a question is a matter of degree, taking account of all the circumstances, then an appellate court should show some circumspection before interfering with the decision at first instance: Beynon v Customs and Excise Commissioners [2005] 1 WLR 86 at [27]. In particular, once as a matter of law a receipt or an expenditure is capable of being regarded as capital or income (as the case maybe), then the Commissioners’ decision should be capable of review only on Edwards v Bairstow 1956 AC14 principals.’

Judges:

Buxton LJ, Moses LJ, Lawrence Collins LJ

Citations:

[2007] EWCA Civ 1207

Links:

Bailii

Jurisdiction:

England and Wales

Citing:

Cited – London and Thames Haven Oil Wharves Ltd v Attwooll CA 1966
When asking whether a payment of damages was a capital or income receipt, the court should ask whether the sum which the trader ought to have received have been credited as an income receipt of the trade? . .
Appeal from – Able (UK) Ltd v Revenue and Customs ChD 19-Oct-2006
Appeal by way of case stated against a decision of the General Commissioners as to whether a certain compensation payment received by the appellant under section 31(3) of the Land Compensation Act 1961 was income or capital. The General . .
Cited – Able (UK) Holdings Ltd v HM Inspector of Taxes ChD 30-Jun-2006
. .

Cited by:

Cited – HM Revenue and Customs v Weight Watchers (UK) Ltd ChD 21-Jan-2008
The court was asked whether the weight-watchers program which included attendance at a course and a supply of supporting materials was one single standard-rated supply or separate supplies of zero-rated printed materials and standard-rated support . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 12 July 2022; Ref: scu.261448

Loss relief available but reduced by contributions from others.

Citations:

Gazette 13-Jan-1993

Statutes:

Capital Gains Tax Act 1979 136-4

Jurisdiction:

England and Wales

Corporation Tax

Updated: 10 July 2022; Ref: scu.83026

Europa Freedom of establishment – Free movement of capital Corporation tax Loan interest paid to a related company resident in another Member State or in a non-member country Interest treated as a distribution Cohesion of the tax system Tax avoidance).

Citations:

[2007] EUECJ C-524/04, [2006] EUECJ C-524/04

Links:

Bailii, Bailii

Jurisdiction:

European

Corporation Tax

Updated: 10 July 2022; Ref: scu.251136

The Revenue sought to disallow for industrial buildings allowance sums expended on warehouse premises which were to be used to store window products imported for use in other manufacturing processes.
Held: The Revenue’s appeal succeeded. ‘The question under s.18(1) is whether the warehouse is in use for the purposes of a trade which consists in the storage of qualifying goods and materials.’ and ‘for an operation to be part of a trade within the meaning of s.18(2) it must itself be an activity in the nature of a trade. As s.18 itself demonstrates a trade for these purposes is not limited to the selling of goods and can include both manufacturing and processing operations. But like Lightman J, I am not persuaded that storage as a trade in s.18(1) and as part of a trade in s.18(2) involve the application of quite different tests. Section 18(2) operates only to expand the definition contained in s.18(1) not to alter it. ‘ Although the storage of the qualifying goods in this case is carried out in a separate building and on a quite different scale, it is nonetheless carried out to support the company’s wholesale trading operation and not as a trading or commercial activity in itself. On my view of s.18(2) that is not enough.

Judges:

Patten J

Citations:

[2006] EWHC 1832 (Ch), Times 11-Aug-2006, [2006] BTC 829, [2006] STI 1919, [2007] STC 721

Links:

Bailii

Statutes:

Capital Allowances Act 1990, Capital Allowances Act 2001

Jurisdiction:

England and Wales

Citing:

Cited – Kay v Burrows HL 1931
The House considered whether premises (the greater part of which was used for the storage of rags awaiting processing, sorting or subsequent despatch) fell within the proviso to s.3(1) which excluded premises ‘primarily occupied and used [for the] . .
Cited – Dale (HM Inspector of Taxes) v Johnson Brothers 1951
(Year?) The taxpayer claimed an industrial buildings allowance against his tax liabilities for a warehouse used as storage as a trade in itself. Two thirds of the use was for storage of finished goods awaiting collection or delivery. The taxpayers . .
Cited – Saxone Lilley and Skinner (Holdings) Ltd v Commissioner of Inland Revenue HL 1967
The taxpayer company was the parent company of a group of subsidiaries, one of which traded as the manufacturer and retailer of shoes. The others either manufactured or sold shoes. The company built a warehouse which was let to a warehousing . .
Cited – Bestway (Holdings) Ltd v Luff (Inspector of Taxes) ChD 4-Mar-1998
The taxpayer company operated a wholesale cash and carry business from a number of self-service supermarkets. The stores sold groceries, household goods, tobacco, confectionery and various kinds of alcohol. Although the buildings were not open to . .
Wrongly Decided – Crusabridge Investments Ltd v Casings International Limited 1979
The landlord of light industrial premises sought damages from his tenant for breach of the user covenant in the lease. This permitted the premises to be used, inter alia, as an ‘industrial building or structure’ as defined by the Capital Allowances . .
Cited – Kilmarnock Equitable Co-operative Society Ltd v Inland Revenue Commissioners SCS 16-Feb-1966
Income Tax, Schedule D – Profits Tax – Capital allowances – Industrial building or structure – Building for screening and packing coal – Whether coal subjected to a process – Whether building used for purpose ancillary to a retail shop – Income Tax . .
Cited – Vibroplant Ltd v Holland (HM Inspector of Taxes) CA 1980
The use of the buildings for servicing and repairing the plant which Vibroplant wished to hire out, was an essential part of Vibroplant’s business of plant hire operators and part of their trade. Although not required to decide the point, the court . .
Cited – Rolls Royce Motors Ltd v Bamford 1976
The court was asked whether the new state owned company which took over some of the assets and undertaking of Rolls Royce Ltd following its insolvency was entitled to carry forward and set against its profits the losses of the old company up to the . .
At SCIT – Maco Door and Window Hardware (UK) Ltd v Revenue and Customs SCIT 25-Oct-2005
SCIT CAPITAL ALLOWANCES – industrial buildings allowances – building used to house goods manufactured by the Appellant’s Austrian parent company for sale to wholesalers in the UK to be used in manufacture – . .

Cited by:

Appeal from – Maco Door and Window Hardware (UK) Ltd v HM Revenue and Customs CA 19-Jun-2007
Correct classification, for the purposes of capital allowances, of expenditure on a building provided for the business of the appellant. . .
At Divisional Court – Maco Door and Window Hardware (UK) Ltd v Revenue and Customs HL 30-Jul-2008
The House was asked whether a warehouse used to store purchases made by the company from its parent company in Austria, was an ‘industrial building or structure’. It was agreed that the facility was used for the storage of materials for use in later . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 07 July 2022; Ref: scu.243331

Profits Tax – Trade or business transferred – Election under Section 36 (4), Finance Act, 1947 – Transferor company wound up after selling shares in successor – Distributions exceed paid-up share capital – Whether distribution charge incurred – Finance Act, 1947 (10 and 11 Geo. VI, c.35), Section 30(3), 35 (1) (c), 36 (4) and 43 (1).

Citations:

[1961] UKHL TC – 39 – 707

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 28 June 2022; Ref: scu.559964

The parties disputed the taxation of currency contracts in the form of front end payments on two hedging transaction.

Judges:

Mummery, Laws, Moses LJJ

Citations:

[2009] EWCA Civ 622, 79 TC 691, [2009] BTC 306, [2009] STI 2024, [2009] STC 2459

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 11 June 2022; Ref: scu.347201

Buxton LJ: ‘The issue therefore is one of simple statutory construction. Can the expression ‘payment’ when used in section 87 of the 1970 Act, or ‘pays’ when used both in section 246N(2) of the 1988 Act and section 239 of the 1988 Act, encompass a set-off of the sort that the appellant asserts? In order to succeed, the appellant has to establish, both that those statutory references to payment or paying can potentially include a situation of set-off; and that also that in this case ‘set-off’ was in fact available to the appellant. In my judgment, the appellant fails on both of those scores.’

Judges:

Buxton LJ

Citations:

[2003] EWCA Civ 173

Links:

Bailii

Statutes:

Taxes management Act 1970 87

Jurisdiction:

England and Wales

Citing:

Cited – Hanak v Green CA 1958
A builder was sued for his failure to complete the works he had contracted for. The buider sought a set-off against that claim of three of his one claims. One, under the contract, was for losses from the defendant’s refusal to allow his workmen . .
Cited – Aries Tanker Corp v Total Transport Ltd; The Aries HL 1977
Claims for freight charges are an exception to the general rule that all claims between parties must be resolved in one action. A claim for freight cannot be a claim ‘on the same grounds’ as a counter-claim for loss or damage arising out of the . .

Cited by:

Appeal from – Burton (Collector of Taxes) v Mellham Ltd HL 15-Feb-2006
The claimant sought interest on an overpayment of Advance Corporation Tax. The tax itself had been paid late, and the Collector claimed a set off.
Held: The claim to DTR could not be described as an attempt at self-help. It had a statutory . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 07 June 2022; Ref: scu.181110

Company must exist for purpose of trading to get relief on interest on loan.

Citations:

Ind Summary 12-Jul-1993

Jurisdiction:

England and Wales

Corporation Tax

Updated: 04 June 2022; Ref: scu.83199

Freedom to provide services – Commercial tax on capital and operating profit – Reinstatement in tax base – Exemption not applicable to lessee of property whose owner is established in another Member State and therefore not subject to tax

Citations:

C-294/97, [1999] EUECJ C-294/97, [1999] ECR I-7447

Links:

Bailii

Jurisdiction:

European

Cited by:

Cited – Foulser and Another v HM Inspector of Taxes ChD 20-Dec-2005
The taxpayer company entered into an arrangement in which shares were purchased by a company based in Ireland and resold. A claim was made for holdover relief.
Held: The scheme failed. The restriction imposed did not infringe the right of . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 04 June 2022; Ref: scu.162207

The tax exemption attracted to interest on some government securities in favour of foreign residents was lost by a foreign resident company when it carried on a long term life assurance business here on a mutual basis through an office here. The interest was taxable under Schedule C. The business profits restriction in the Act was the income minus expenditure basis. The business described was a trade.

Citations:

Times 22-Nov-2000

Statutes:

Finance Act 1940 60

Jurisdiction:

England and Wales

Corporation Tax

Updated: 04 June 2022; Ref: scu.83390

Provision in airline accounts for engine overhauls was proper accounting.

Citations:

Times 20-Jul-1994

Jurisdiction:

England and Wales

Corporation Tax

Updated: 02 June 2022; Ref: scu.82567

The appellants entered into partnerships with a film production company. By doing so they intended to make available to themselves first year allowances on the capital expenditure incurred. Loan agreements protected them from any eventual loss.
Held: Money which had been spent mainly for trading had the benefit of the tax allowances whatever the motive behind for structure of the transactions. Even if a fiscal motive was the sole or paramount motive for a transaction, that would not deprive the action of its proper nature. The legal effect was of a trading transaction with a capital expenditure, and the case was remitted for consideration on that basis. A composite transaction which could fairly be described as involving a ‘conjuring trick’, artificiality and self-cancelling elements, should nonetheless not be called a sham, in the relevant sense.

Judges:

Lord Goff of Chieveley

Citations:

Gazette 06-May-1992, [1992] 1 AC 655, [1992] CLY 611, [1992] 2 WLR 469, [1992] STC 226

Jurisdiction:

England and Wales

Citing:

Applied – Craven (IOT) v White (Stephen); Inland Revenue Commissioners v Bowater Property Developments HL 1989
In Craven, the taxpayers owned shares in Q Ltd. In early 1976 they began to negotiate with C Ltd for a merger of the two companies and steps were taken to establish an Isle of Man holding company to act as a vehicle for the taxpayers’ shares should . .
Cited – W T Ramsay Ltd v Inland Revenue Commissioners HL 12-Mar-1981
The taxpayers used schemes to create allowable losses, and now appealed assessment to tax. The schemes involved a series of transactions none of which were a sham, but which had the effect of cancelling each other out.
Held: If the true nature . .

Cited by:

Cited – New Angel Court Ltd v Adam (Inspector of Taxes) ChD 25-Jul-2003
The taxpayer company employed a subsidiary company through which it conducted its trade in land. It then sought to represent the profits from that subsidiary within its own accounts as trading profits for corporation tax purposes. The commissioner . .
Cited – Revenue and Customs v Dempster (T/A Boulevard) ChD 24-Jan-2008
The revenue wished to refuse a claim to set off input tax for two transactions involving the alleged purchase of software. They said the transactions were a sham.
Held: The revenue’s appeal failed.
Briggs J said: ‘the critical question . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 19 May 2022; Ref: scu.80334

Housing association which was registered under Act is an investment company and is to carry a profit charge.

Citations:

Times 01-Jan-1997

Statutes:

Industrial and Provident Act 1965, Income and Corporation Taxes Act 1988 130

Jurisdiction:

England and Wales

Corporation Tax

Updated: 19 May 2022; Ref: scu.79477

Where a company sought to claim reliefs going back over different tax years, there was no rule requiring such reliefs to be claimed chronologically, but the company could arrange the claims against the several tax years as they best thought fit. There was no express power to order them, but the test was the absence of any law requiring a particular order to be used. The section dealt with only one claim, and said nothing about how two claims should be ordered.

Citations:

Times 24-May-2000, [2000] EWCA Civ 156

Links:

Bailii

Statutes:

Income and Corporation Taxes Act 1988 239(3)

Jurisdiction:

England and Wales

Citing:

Appeal from – Carr (Inspector of Taxes) v Armpledge Ltd; Same v Fielden and Ashworth Ltd ChD 12-Oct-1998
A company’s settlement of its tax affairs had to be dealt with in chronological order even though it would be from it’s point of view more tax efficient to have them dealt with in reverse order. No right of choice was given to a taxpayer. . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 19 May 2022; Ref: scu.78912

A distinction is to be found between the construction of plant and the equipment installed. The Court should examine the function of a structure to decide if it was a plant or a building for allowance.

Citations:

Gazette 09-Oct-1996, Times 01-Aug-1996

Statutes:

Capital Allowances Act 1990 24

Corporation Tax

Updated: 18 May 2022; Ref: scu.78546

A claim to deal on accounts which had been drawn over 104 weeks disallowed.

Citations:

Gazette 12-May-1993

Statutes:

Finance Act 1981

Corporation Tax

Updated: 18 May 2022; Ref: scu.78275

(Year?) The taxpayer claimed an industrial buildings allowance against his tax liabilities for a warehouse used as storage as a trade in itself. Two thirds of the use was for storage of finished goods awaiting collection or delivery. The taxpayers were the sole selling agents for various manufacturers and were obliged under the agreement with them to store sufficient products to enable prompt delivery to be made to customers. They relied on s.8(1)(d)(iii) of the 1945 Act.
Held: The claim was rejected. The trade carried on at the warehouse was not storage alone, but also the disposal of the goods as selling agents.
Sheil J said: ‘That Section, so far as it is invoked here, contemplates that the use of the building must be for a trade and that trade, so far as the use is concerned, must be a storage trade. It will not do that the trade is storage plus something else or something else plus storage. It must be simply a keeping or custody. When one considers the use of the two-thirds of this building it cannot be said that there was simply a keeping or custody in that part of it. The agreements required a constant active movement of the goods by the Respondents, a disposal of them by the Respondents ‘

Judges:

Sheil J

Citations:

(1951) 32 TC 487

Statutes:

Income Tax Act 1945 8

Cited by:

Cited – Revenue and Customs v Maco Door and Window Hardware (Uk) Ltd ChD 19-Jul-2006
The Revenue sought to disallow for industrial buildings allowance sums expended on warehouse premises which were to be used to store window products imported for use in other manufacturing processes.
Held: The Revenue’s appeal succeeded. ‘The . .
Explained – Crusabridge Investments Ltd v Casings International Limited 1979
The landlord of light industrial premises sought damages from his tenant for breach of the user covenant in the lease. This permitted the premises to be used, inter alia, as an ‘industrial building or structure’ as defined by the Capital Allowances . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 10 May 2022; Ref: scu.244452

Even a large structure used for the purposes of the trade may be capable of being plant. In this case a dry dock was used in trade of ship builders, ship repairers and marine engineers.

Citations:

[1969] 1 WLR 675

Jurisdiction:

England and Wales

Cited by:

Cited – Shove (Inspector of Taxes) v Lingfield Park 1991 Ltd ChD 21-Jul-2003
The taxpayer, a race track owner, sought to claim the cost of laying an artificial all-weather race track surface as a capital allowance. The commissioners had found that it retained a separate identity from the grass, requiring maintenance and so . .
Cited – Gray (Inspector of Taxes) v Seymours Garden Centre (Horticulture) CA 31-May-1995
A ‘Planteria’ for the growing and storage of plants pending sale was premises, or a building, and not plant; no allowance was available. In considering the appeal, ‘the question for this Court, as it was for the Judge, is whether the facts found by . .
Cited – Lingfield Park (1991) Limited v Shove CA 31-Mar-2004
The taxpayers sought capital allowances on the costs of installing an artificial all-weather race track.
Held: The track was not either plant or machinery, and the taxpayer was not eligible for the relief. The only reasonable conclusion was . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 29 April 2022; Ref: scu.185850

Expenditure on modernising restaurants with shop fronts, floor and wall tiles, wall finishes, suspended ceilings, raised floors, fire doors and fire proofings was held not to be plant. The court asked what marks indicate that a structure premises of plant, for capital allowances purposes: ‘It is proper to consider the function of the item in dispute. But the question is what does it function as? If it functions as part of the premises it is not plant.’

Judges:

Hoffmann J, Fox LJ, Lloyd LJ

Citations:

[1988] SDTC 149, (1988) 61 TC 51

Jurisdiction:

England and Wales

Cited by:

Cited – Shove (Inspector of Taxes) v Lingfield Park 1991 Ltd ChD 21-Jul-2003
The taxpayer, a race track owner, sought to claim the cost of laying an artificial all-weather race track surface as a capital allowance. The commissioners had found that it retained a separate identity from the grass, requiring maintenance and so . .
Cited – Lingfield Park (1991) Limited v Shove CA 31-Mar-2004
The taxpayers sought capital allowances on the costs of installing an artificial all-weather race track.
Held: The track was not either plant or machinery, and the taxpayer was not eligible for the relief. The only reasonable conclusion was . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 29 April 2022; Ref: scu.185847

A transaction might be so clearly inspired by fiscal considerations that its shape and character as a trading transaction would be insufficient to preserve its tax value as such.

Citations:

[1984] 1 WLR 1328

Jurisdiction:

England and Wales

Cited by:

Cited – New Angel Court Ltd v Adam (Inspector of Taxes) ChD 25-Jul-2003
The taxpayer company employed a subsidiary company through which it conducted its trade in land. It then sought to represent the profits from that subsidiary within its own accounts as trading profits for corporation tax purposes. The commissioner . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 29 April 2022; Ref: scu.185842

Corporation Tax – National Tax Legislation Making The Transfer of The Losses – Judgment

Citations:

ECLI:EU:C:2018:526, C-28/17, [2018] EUECJ C-28/17

Links:

Bailii

Jurisdiction:

European

Corporation Tax

Updated: 25 April 2022; Ref: scu.620034

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:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 25 April 2022; Ref: scu.619364

Income Tax/Corporation Tax : Other – CORPORATION TAX – appeal against paragraph 1 Schedule 36 information notice – whether burden of proof on HMRC – whether documents reasonably required for the purpose of checking the appellant’s tax position – appeal dismissed

Citations:

[2018] UKFTT 232 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 14 April 2022; Ref: scu.609291

No capital allowances for car wash structures. They were part of premises, not plant.

Judges:

Carnwath J

Citations:

Times 11-Dec-1995

Statutes:

Capital Allowances Act 1990 22 24

Jurisdiction:

England and Wales

Cited by:

Appeal from – H M Inspector of Taxes (Atwood) v Anduff Car Wash Limited CA 17-Jul-1997
Capital allowances.
The taxpayer operated automatic car wash sites. It claimed capital allowances for the entirety of a wash hall, housed within a building incorporating washing machinery and control equipment, and surrounded by tarmac areas . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 10 April 2022; Ref: scu.78021

The income from investments set aside to cover future liabilities was not trading income.

Citations:

Gazette 09-May-1996, Times 29-Mar-1996

Statutes:

Income and Corporation Taxes Act 1988 393(8)

Citing:

Appeal from – Nuclear Electric Plc v Bradley (Inspector of Taxes) CA 13-Nov-1995
Income on funds set aside but not allocated for expenditure not trading income . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 09 April 2022; Ref: scu.84383

A Life Assurance company’s management expenses were not deductible as quantum of profit.

Citations:

Times 05-Jul-1996

Statutes:

Finance Act (No 2) Act 1992 65

Corporation Tax

Updated: 08 April 2022; Ref: scu.82545

Accruals accounting for engines repaired four yearly was appropriate.

Citations:

Ind Summary 01-Aug-1994

Corporation Tax

Updated: 08 April 2022; Ref: scu.82566

Corporation tax – Purchase by traders of partnership interests and adherence to partnerships followed by realisation and distribution by partnerships of receivables – whether purchase price of partnership interests and contributions to capital of partnerships were capital or revenue expenditure – if revenue, whether incurred wholly and exclusively for purposes of traders’ trades – if revenue incurred wholly and exclusively, whether HMRC entitled to raise further issue not in closure notice – whether partnership profits distributed to traders subject to two tax computations

Citations:

[2018] UKUT 69 (TCC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 07 April 2022; Ref: scu.608590

The tax payers had become involved in tax arrangements later fund to be tax avoidance.
Held: The appeal failed: ‘the materials before the FTT did not justify the attribution of any of the debits claimed by LGI to anything other than the ‘unallowable purpose’. LGI never supplied particulars of what loan(s) it claimed would have been made to it at what rate(s) of interest and for what period(s) had it not adopted the Deloitte scheme. No such details were, for example, given in LGI’s Notice of Appeal to the FTT, which simply contended that ‘the deductions for interest are allowable for corporation tax purposes’ and that ‘the non-trading loan relationship debits should be allowed against trading profits’. Again, Mr Turner’s witness statement said that the Novations ‘could have been replaced by the payment of dividends’, but did not expand on how or, in particular, what (if anything) LGI would have borrowed for the purpose. ‘

Citations:

[2018] EWCA Civ 549

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 06 April 2022; Ref: scu.606480

Income Tax/Corporation Tax : Other

Citations:

[2018] UKFTT 20 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 04 April 2022; Ref: scu.604353

Judges:

Patten, Sales LJJ

Citations:

[2018] EWCA Civ 31, [2018] WLR(D) 43

Links:

Bailii, WLRD

Jurisdiction:

England and Wales

Corporation Tax

Updated: 03 April 2022; Ref: scu.603722

Income Tax/Corporation Tax : Appeal

Citations:

[2017] UKFTT 846 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 02 April 2022; Ref: scu.600984

CORPORATION TAX – application for ‘closure’ notices – para 33 of Schedule 18 to FA 1998 – whether there was a valid enquiry notice under para 24 of Schedule 18 to FA 1998; no – Tribunal has no jurisdiction to exercise – application refused

Citations:

[2017] UKFTT 842 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 02 April 2022; Ref: scu.600968

Corporation Tax : Business Assets Roll-Over Relief

Citations:

[2017] UKUT 389 (TCC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 01 April 2022; Ref: scu.599435

Income Tax/Corporation Tax : Employment Income – Income tax, PAYE, NICs and corporation tax – Employee Benefit Trusts – whether contributions to sub-funds established for individual employees or loans from sub-funds to those employees constituted earnings for income tax and NIC purposes – whether corporation tax deduction available

Citations:

[2017] UKFTT 692 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 01 April 2022; Ref: scu.598979

Corporation Tax : Group Relief

Citations:

[2017] UKUT 394 (TCC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 30 March 2022; Ref: scu.595607

(Income Tax/Corporation Tax : Other) INCOME TAX – CORPORATION TAX – Sch 36 Notices – reasonably required – higher threshold of ‘reason to suspect’ under para 21(6) -documents required to transfer ownership of land – meaning of failure to comply so as to incur a penalty – Sch 36 Notices partly upheld, partly set aside – penalties upheld.

Citations:

[2017] UKFTT 616 (TC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 28 March 2022; Ref: scu.592643

ECJ Failure of a Member State to fulfil obligations Free movement of capital Article 56 EC Articles 31 and 40 of the EEA Agreement Direct taxation Withholding at source on outgoing dividends Set-off at the place of establishment of the recipient of the dividend, pursuant to a convention for the avoidance of double taxation

Citations:

[2009] EUECJ C-540/07

Links:

Bailii

Jurisdiction:

European

Citing:

Opinion – Commission v Italy C-540/07 ECJ 16-Jul-2009
ECJ (Taxation) Failure of a Member State to fulfill obligations) Free movement of capital Article 56 EC Articles 31 and 40 of the EEA Agreement Direct taxation Withholding tax on outgoing dividends Deduction to . .
Lists of cited by and citing cases may be incomplete.

Corporation Tax

Updated: 27 March 2022; Ref: scu.588172

Appeal from closure notices

Citations:

[2017] UKUT 205 (TCC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 26 March 2022; Ref: scu.584691

INFORMATION NOTICE – PENALTIES – whether wording of penalty notice issued by HMRC allowed further time for compliance with information notice – no – appeal dismissed

Citations:

[2017] UKUT 215 (TCC)

Links:

Bailii

Jurisdiction:

England and Wales

Corporation Tax

Updated: 26 March 2022; Ref: scu.584690