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Marina Silver (TC7103)
The decision of the First-tier Tribunal to allow the taxpayer’s appeal against HMRC’s top slicing relief calculation was reviewed by Tim Good in ‘Silver wins gold’ (Taxation 23 May 2019 page 8).
Keith Gordon barrister at Temple Tax Chambers said: ‘This case confirms a point which Tim Good has raised in a couple of recent articles (‘That knowing look’ and ‘It’s all gone Pete Tong’). The tribunal’s decision is obviously correct as it reflects both common sense and the statutory wording. The only thing which it appears to disagree with is the programming of HMRC’s computer.
‘I hope HMRC will graciously accept defeat. However I do have a nagging feeling that they might find it easier to appeal against the decision than to reprogram their own tax calculation software. If they were to do so I hope that they would make it clear...
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