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B D’Angelin v HMRC

In B D’Angelin v HMRC [2024] UKFTT 462 (TC) (30 May 2024) the FTT dismissed the taxpayer’s appeal against a closure notice withdrawing his remittance basis business investment relief in respect of an investment in a company controlled by the taxpayer. His use of a director’s loan account to fund personal expenses amounted to the extraction of value from the company. 

The taxpayer was resident but not domiciled in the UK and was a remittance basis user. In 2016 he remitted £1.5m of his foreign income to the UK and invested in a UK company in which he was the sole shareholder and director. The company traded as advisers to global clients and family holdings. He claimed business investment relief under ITA 2007 s 809VA in respect of the investment with the effect that the £1.5m was treated as not having been remitted to the UK (and so not taxable)....

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