In E Thomson and others v HMRC [2018] UKFTT 396 (16 July 2018) the FTT found that the appellants had not been trading in derivatives so that their loss was not allowable (ICTA 1988 s 380).
The three appellants had entered into a financial contract described as a contract for differences (CFD). They contended that they had entered into the contract in the course of a trade of dealing in derivatives and that the CFD had resulted in a loss which could be set against their other taxable income. HMRC refused the claims for loss relief as it considered that the appellants were not carrying on a trade on a commercial basis with a view to profit. It also charged the appellants penalties for negligent completion of their tax returns (TMA 1970 s 95).
The FTT observed that none of the...
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In E Thomson and others v HMRC [2018] UKFTT 396 (16 July 2018) the FTT found that the appellants had not been trading in derivatives so that their loss was not allowable (ICTA 1988 s 380).
The three appellants had entered into a financial contract described as a contract for differences (CFD). They contended that they had entered into the contract in the course of a trade of dealing in derivatives and that the CFD had resulted in a loss which could be set against their other taxable income. HMRC refused the claims for loss relief as it considered that the appellants were not carrying on a trade on a commercial basis with a view to profit. It also charged the appellants penalties for negligent completion of their tax returns (TMA 1970 s 95).
The FTT observed that none of the...
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