Nicholas Walewski v The Commissioners for HM Revenue and Customs [2021] UKUT 0133 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Marcus Smith and Judge Rupert Jones on 15 June 2021
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INCOME TAX – CORPORATION TAX – Mixed Partnership Rules – Sections 805A-E Income Tax (Trading and Other Income) Act 2005 – s805C – increase in the profit share of an individual partner by so much of the amount of the corporate partner’s profit share is attributable to the individual’s power to the enjoy the corporate’s profit share – appeal dismissed
Published 16 June 2021