Russell Price v HMRC

In Russell Price v HMRC [2014] UKFTT 929 – 3 October 2014 the FTT found that a discovery assessment was valid.

Mr Price had claimed £70 000 share loss relief under ICTA 1988 s 574. HMRC had issued a discovery assessment denying the claim on the ground that Mr Price’s advisers had failed to disclose in his return that the relevant company was a subsidiary. Furthermore Mr Price’s bank account records showed entries which exceeded his taxable income. Mr Price explained that these corresponded to a loan but that he did not have the relevant documents having fled Cyprus due to threats from a business rival.

The FTT found that HMRC had been correct in denying share loss relief on the ground that the company had been a subsidiary. The FTT also found that Mr Price’s advisers had represented that the company had been a qualifying...