The Court of Appeal rejected the taxpayer’s appeal, upholding the earlier UT and FTT decisions that distributions received were dividends, but were not of a capital nature and were therefore chargeable to income tax
Section 415 Income Tax (Trading and Other Income) Act 2005 – whether director’s loan was released – no – whether director’s loan was written off – no – appeal allowed
The Court of Appeal overturned the decision of the Upper Tribunal (UT) and determined that pre-construction expenditure on surveys and studies in offshore windfarms qualified for capital allowances
The England and Wales Court of Appeal held that redress payments made by the taxpayers to consumers and charities pursuant to agreements made in settlement of regulatory investigations were deductible for the purposes of corporation tax
The taxpayer claimed capital allowances for the wall’s construction costs, but HMRC denied the claim, arguing that the wall was not plant or machinery
One of a series of grouped determinations on the status of an investment in a fund. Each of the appellants had been an investor in a fund. They had each treated that investment as being subject to CGT treatment
The First-tier Tribunal (FTT) considered whether redress payments made to individuals who were wrongly treated as being ineligible for continuing healthcare included an element of “‘interest”’ for income tax purposes
Land and Buildings Transaction Tax – whether residential or non-residential – whether used as an office on the effective date – no – whether used as a residential property on the effective date – no – whether suitable for use as residential property – yes – appeal refused
The First-tier Tribunal determined that shares in a holding company did not qualify as ‘relevant business property’ for the purposes of business property relief for inheritance tax purposes
The First-tier Tribunal held that a trade had not commenced within two years of the share issue (the EIS deadline) as the the trade infrastructure was not yet in place to enable operational activities to commence