The Upper Tribunal (UT) in Altrad Services Ltddecides that a disclosed arrangement intended to deliver capital allowances in respect of ‘magical’ expenditure survived HMRC’s Ramsay challenge. The UT in BlackRockallows HMRC’s appeal on transfer pricing and, although not necessary to determine the appeal, finds that all of the debits were attributable to the unallowable purpose and none to the commercial purpose. HMRC’s appeal to the UT in the Euromoney case fails as the UT agrees with the decision of the FTT on the application of the purpose test in TCGA 1992 s 137. Recent cases show that it is currently taking nearly a year for determination of applications to appeal to the Supreme Court.
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The Upper Tribunal (UT) in Altrad Services Ltddecides that a disclosed arrangement intended to deliver capital allowances in respect of ‘magical’ expenditure survived HMRC’s Ramsay challenge. The UT in BlackRockallows HMRC’s appeal on transfer pricing and, although not necessary to determine the appeal, finds that all of the debits were attributable to the unallowable purpose and none to the commercial purpose. HMRC’s appeal to the UT in the Euromoney case fails as the UT agrees with the decision of the FTT on the application of the purpose test in TCGA 1992 s 137. Recent cases show that it is currently taking nearly a year for determination of applications to appeal to the Supreme Court.
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
