In Hopscotch v HMRC, a redevelopment of residential property was not considered to be part of a property development trade for ATED purposes. In B Edwards v HMRC, penalties imposed for late filing in circumstances where the taxpayer was not liable to tax were deemed not to be disproportionate. The GAAR panel decided that a scheme designed to avoid remuneration and distribution treatment using bonds was not a reasonable course of action. In S Hurst v HMRC, the FTT decided that a notice to file was invalid as HMRC had already established the amount of tax due through a P800.
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In Hopscotch v HMRC, a redevelopment of residential property was not considered to be part of a property development trade for ATED purposes. In B Edwards v HMRC, penalties imposed for late filing in circumstances where the taxpayer was not liable to tax were deemed not to be disproportionate. The GAAR panel decided that a scheme designed to avoid remuneration and distribution treatment using bonds was not a reasonable course of action. In S Hurst v HMRC, the FTT decided that a notice to file was invalid as HMRC had already established the amount of tax due through a P800.
If you are not a subscriber, subscribe now to read this content.
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