In J Keighley and another v HMRC [2024] UKFTT 30 (TC) (8 January 2024) the First-tier Tribunal (FTT) considered a number of issues arising from an enquiry into the CT return of a company. The main issues were the payment of personal expenses of a shareholder by the company and the tax treatment of the write off of a loan made by the company.
The first appellant K was a shareholder and member of the senior management team of a company P Ltd which imported doormats. He used a company credit card for substantial personal expenses which was then settled by the company but no adjustments were made in the company’s accounts or in his personal returns to account for the tax and NIC arising. HMRC issued discovery assessments and penalties to K based on deliberate behaviour for all years from 2001 to 2017. HMRC had...
