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Tower MCashback

Dalla Jenney and Chris Bates of Norton Rose LLP consider the recent High Court judgment in the Tower MCashback case
In a robust judgment allowing the taxpayer's appeal Henderson J overturned the decision of the Special Commissioners in Tower MCashback LLP1 and another v HMRC [2008] EWHC 2387 (Ch). The decision addressed two important questions. The substantive question was to what extent a limited liability partnership had incurred expenditure qualifying for a first-year capital allowance on the acquisition of a software licence. The procedural question was whether HMRC can introduce new grounds for denying relief in an appeal where a different justification has been given in the notice closing the Inspector's enquiry into the...

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