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Referring to loan relationships, ADAM CRAGGS illustrates the importance of well-presented evidence before the tax tribunal
KEY POINTS
- The facts of the MJP case.
- The importance of documentary evidence.
- The conditions for relief to be given for a loan waiver.
- The lessons to learn from this case.
- Documents need to be supported by credible evidence.
Taxpayers particularly sophisticated ones are well aware that tax law can be a complex subject containing a myriad potential pitfalls for the unwary. What is sometimes less well-known is that taking a case to the independent tax tribunals often raises difficult evidential issues which require careful navigation.
This was highlighted in the recent decision of the First-tier Tribunal in MJP Media Services Limited (TC 586).
The decision
MJP Media Services Limited (MJP) claimed a deduction of £6 690 000 for a loan relationship debit in its 2004 tax computation. HMRC rejected the claim...
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