Spring Salmon & Seafood Ltd v HMRC

In Spring Salmon & Seafood Ltd v HMRC (No. 2) (TC02723 – 11 June) the Revenue began an investigation into a company (S). This investigation was settled by a contract settlement in early 2004 under which S paid tax of £525 000. Later in 2004 HMRC began an enquiry into S’s returns for 2002 and 2003 (in which S claimed relief for amortisation of goodwill). In 2006 HMRC also began an enquiry into S’s returns for 2004 and 2005 (in respect of which S had submitted a covering letter claiming terminal loss relief). In 2011 HMRC issued closure notices rejecting S’s claims. S appealed contending firstly that its claim to terminal loss relief had become final and conclusive and additionally that its tax liability for 2002 and 2003 had already been included as part of the 2004 contract settlement. Judge Mosedale rejected S’s contention regarding...