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Tax Cases and Appeals Crown Copyright
2019-08-29
Capital gains tax - Entrepreneurs' relief - whether appellants company was a trading company during the relevant period - whether there were substantial non-trading activities
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Tax Cases and Appeals Crown Copyright
2019-08-06
Capital gains tax – Payment under a guarantee in respect of loan to company – Whether allowable loss – Whether ‘qualifying loan’ – Whether company commenced trading – Appeal allowed
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Tax Cases and Appeals Crown Copyright
2019-07-26
LLPs established to carry on activities relating to the production of films and games – individual members of the LLPs making capital contributions for membership – funding also coming from commissioning distributor – Whether activities carried on by the LLPs constituted a trade – Whether activities of the LLPs carried on with a view to profit – Whether expenditure incurred by the LLPs equal to 100% of production budget of film or game – Whether expenditure incurred wholly or exclusively for purposes of LLPs’ trade – Whether LLPs’ accounts compiled in accordance with generally accepted accounting practice – Whether LLPs’ expenditure on film and games rights was capital expenditure for tax purposes – Income Tax (Trading and Other Income) Act 2005, ss 25, 26, 33, 34, 863 – Corporation Tax Act 2009 ss 46, 47, 53, 54, 1262, 1273
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Tax Cases and Appeals Crown Copyright
2019-03-25
Examination of the principles of free movement of establishment; failure to grant relief under the equivalent of s617 TCA 1997
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Ian Coll v HMRC [2019] UKFTT 87 (TC) (Ian Coll v HMRC [2019] UKFTT 87 (TC) )

Tax Cases and Appeals Crown Copyright
2019-01-24
Taxpayer had a reasonable excuse for the late filing of returns because of the failures of accountant
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Tax Cases and Appeals Crown Copyright
2019-01-22
Although a scheme to generate capital losses failed under the value-shifting rules, a related loan waiver was not subject to income tax
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