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Decision Number: |
TC 02501 |
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Appellant:
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Albermarle 4 LLP |
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Respondent:
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The Commissioners for Her Majesty's Revenue & Customs |
Chairmen / Special
Commissioners: |
Swami RAGHAVAN
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Date Of Decision:
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30/01/2013 |
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Main Category:
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INCOME TAX/CORPORATION TAX |
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Main Subcategory:
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Losses |
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Notes:
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INCOME TAX –Losses – whether losses relating to purchase and resale of
commercial properties by appellant attributable to appellant’s UK property
business (s264 Income Tax (Trading and Other Income Act) 2005) or
whether the losses were trading losses – losses were trading losses – whether
“discovery amendment” under s30B(1) Taxes Management Act 1970
(“TMA 1970”) to partnership statement reclassifying trading losses as
property losses fell within conditions in s30B(1) TMA (which required that
profits that ought to be included had not been included or that profits were
or had become insufficient) on basis “profit” included negative amounts –
s30B(1) TMA 1970 not applicable on this basis – appeal allowed in principle |
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Decision(s) to Download:
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TC02501.pdf 
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