Charles Yorke (Allen & Overy) examines a recent decision which debunks a number of assumptions about the approach of both HMRC and tribunals towards accounting evidence.
We have seen very many cases concerning questions of accounting over the past few years. I have counted 12 since the beginning of 2015 more than in the previous ten years put together. This is probably because of the changes made to the loan relationship and derivative contract rules in 2005 and in particular because accounting has taken a preeminent position since then in determining taxable profits. Many of these cases involved structures that were designed to generate a tax benefit that did nothing more than reflect a debit in the accounts.
In the recent case of Ball UK Holdings v HMRC [2017] UKFTT 457 (reported in Tax Journal 30 June 2017) the accounting question is a simple one: should...
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Charles Yorke (Allen & Overy) examines a recent decision which debunks a number of assumptions about the approach of both HMRC and tribunals towards accounting evidence.
We have seen very many cases concerning questions of accounting over the past few years. I have counted 12 since the beginning of 2015 more than in the previous ten years put together. This is probably because of the changes made to the loan relationship and derivative contract rules in 2005 and in particular because accounting has taken a preeminent position since then in determining taxable profits. Many of these cases involved structures that were designed to generate a tax benefit that did nothing more than reflect a debit in the accounts.
In the recent case of Ball UK Holdings v HMRC [2017] UKFTT 457 (reported in Tax Journal 30 June 2017) the accounting question is a simple one: should...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
