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L PAUL FEETUM discusses the recent case of Tower MCashback LLP and another v CRC
KEY POINTS
- The case concerned an incentive package for customers.
- The expenditure on software was as the taxpayer claimed.
- HMRC often raise unexpected additional matters at Special Commissioners' hearings.
- A closure notice must mean what it specifies.
The judgment of Mr Justice Henderson in Tower MCashback LLP and another v CRC was handed down on 13 October 2008 ending (subject to any further appeal) a dispute which has been continuing since notice was first given of an enquiry in June 2005.
It has consumed many hours of professional time and incurred substantial costs but rather curiously has attracted relatively little analysis.
I will not here repeat the salient facts legislation and authorities as these are expressed clearly and concisely by the judge in paragraphs 14 to 71 of the decision once he has...
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