InBloomsbury Verlag gmbh v HMRC[2015] UKFTT 660 (14 December 2015) the FTT found that a company could set off losses which had not been previously computed in a return.
Bloomsbury appealed against corporation tax assessments and penalties relating to the years ending 31 December 2005 and 2007.
Bloomsbury was a German incorporated wholly owned subsidiary of Bloomsbury Publishing Plc (Plc). Plc had acquired it in March 2003 and it had become UK resident as a result of being centrally managed and controlled in the UK. However it had only become aware of its change of residence in 2010. Its tax adviser had then sent to HMRC an ‘error or mistake claim’ under FA 1998 Sch 18 para 51. HMRC had agreed that Bloomsbury had become resident in 2003 and issued notices to file returns for the periods 2004 to 2009....
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InBloomsbury Verlag gmbh v HMRC[2015] UKFTT 660 (14 December 2015) the FTT found that a company could set off losses which had not been previously computed in a return.
Bloomsbury appealed against corporation tax assessments and penalties relating to the years ending 31 December 2005 and 2007.
Bloomsbury was a German incorporated wholly owned subsidiary of Bloomsbury Publishing Plc (Plc). Plc had acquired it in March 2003 and it had become UK resident as a result of being centrally managed and controlled in the UK. However it had only become aware of its change of residence in 2010. Its tax adviser had then sent to HMRC an ‘error or mistake claim’ under FA 1998 Sch 18 para 51. HMRC had agreed that Bloomsbury had become resident in 2003 and issued notices to file returns for the periods 2004 to 2009....
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