Assem Allam v The Commissioners for HM Revenue and Customs [2021] UKUT 0291 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Edwin Johnson and Judge Jonathan Cannan on 23 November 2021
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PROCEDURE – automated notices requiring returns – effect of s103 Finance Act 2020 – effect of s12D TMA 1970 – validity of notices of enquiry under s9A TMA 1970 CAPITAL GAINS TAX – entrepreneurs’ relief – s165A(3) TCGA 1992 – company involved in property development and investment property – nature and extent of activities – whether a trading company INCOME TAX – remittance basis – business investment relief – whether dividend left outstanding on loan account correctly treated as an investment INCOME TAX – transactions in securities – whether main purpose or one of the main purposes of person being a party was to obtain an income tax advantage