.png)
.png)
The taxpayer took part in a tax-planning scheme that resulted after various transactions in a loss of £11.3 million. He included the details in his tax return for 2002/03 but HMRC refused the claim.
He appealed to the First-tier Tribunal which dismissed his appeal saying the whole purpose of the scheme was to avoid tax and it did not work.
The taxpayer appealed to the Upper Tribunal (Tax and Chancery Chamber) which said it was sensible to draw a line between ‘loss’ and ‘real and commercial loss’ where there is a composite transaction.
A single transaction can generate a loss which if it satisfies the statutory rules can be an allowable loss which is usually real or commercial. A composite transaction can also result in a gain or a loss ...
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
