Judge Malcolm Gammie CBE QC, Mr Roland Presho FCMA
Decision released 14 December 2015
Corporation tax – Taxpayer becoming UK resident – Trading losses incurred in first two accounting periods – Late notification of chargeability – HMRC issuing notice to file company tax returns – Whether self-assessment subject to four year time limit – Whether losses ‘existed’ and available to set off against profits of later periods – Discovery assessment and penalty determination – Appeal allowed.
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