W Craig v HMRC

In W Craig v HMRC (TC01786 – 15 February) a landscape gardener (C) claimed a deduction of £110 000 in his accounts for the year ending 30 April 2006 for services allegedly carried out by an associated company (W). HMRC began an enquiry and discovered that W had only been incorporated on 15 March 2006. It had invoiced C for £59 000 on 30 April 2006 and for £51 000 on 1 May 2007. HMRC issued an amendment on the basis that the £59 000 should be spread over the period from 15 March 2006 to 30 April 2007 (so that only a small proportion of it was deductible in the year ending April 2006) and that the £51 000 was deductible in the year ending April 2008. C appealed. The First-tier Tribunal dismissed the appeal holding that the...