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Instances in which the Revenue may argue relief for trading loss is not allowable
KEY POINTS
- Trade loss relief restricted by ITA 2007 s 66 et seq.
- For relief the trade has to be commercial.
- HMRC should only be challenging “extreme cases”.
- A subjective view of the trader can be important.
- Can the trade as currently structured and conducted ever make a profit?
Do you worry about how tough it is for the HMRC officer trying to decide which return to check? I thought not. Nowadays most such selections are made centrally by specialists who have access to sophisticated analysis techniques and a vast amount of data.
Doubtless though readers will know of enquiries where there was no obvious risk; it is actually still quite difficult to effectively target the expensive and precious investigation resource.
It is particularly...
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