The Brain Disorders Research Limited Partnership, Hockin v Revenue and Customs: FTTTx 2 Jul 2015

FTTTx Income Tax/Corporation Tax : Anti-Avoidance – Income Tax – Claim for capital allowances in respect of expenditure on scientific research – Scheme to claim the allowances for a substantially higher amount than that actually applied in undertaking such research – whether the partnership’s whole activity or any part of its activity constituted trading for tax purposes – whether if so, trading losses derived from capital allowances arose in a non-commercial venture – whether pre-payments of interest on two substantial borrowings were allowable – whether the amounts borrowed had been contributed to a partnership and applied wholly for trading purposes – whether ‘interest’ had actually been paid – whether relief was denied by section 787 Taxes Act 1988 – whether certain expenses were deductible – Both Appeals dismissed

[2015] UKFTT 325 (TC)
Bailii
England and Wales

Income Tax

Updated: 02 January 2022; Ref: scu.550300