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Allam: a case full of interest

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Allam considered several diverse issues and highlights the difficulties in overturning findings of fact by the FTT. The UT rejected the taxpayer’s arguments that the closure notices were invalid, and its judgment provides useful guidance on FA 2020 s 103 and TMA 1970 s 12D. The first appeal considered the entitlement to entrepreneurs’ relief and the meaning of a trading company. The second appeal dealt with business investment relief and the nature and disposal of an investment, and illustrates how it is easy for a taxpayer to inadvertently trigger a potentially chargeable event. The third appeal concerned transactions in securities legislation and follows Brebner by confirming that the test of an income tax avoidance purpose was a subjective one.
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