Adam Craggs and Constantine Christofi (RPC) review a recent tribunal decision which considers disclosure and the practical effect of Sanderson.
In J Hicks v HMRC [2018] UKFTT 22 Mr Hicks entered into a tax avoidance scheme devised by Montpelier in 2009 which had been disclosed to HMRC under the disclosure of tax avoidance schemes (DOTAS) rules. The scheme generated a loss for Mr Hicks of some £1.2m. Mr Hicks submitted his tax return for 2008/09 on 27 January 2010 which showed the loss of £1.2m as available to be carried forward and the scheme reference number (SRN) which had been allocated to the scheme by HMRC. HMRC opened an enquiry into the return on 3 December 2010.
Mr Hicks submitted his return for 2009/10 on 28 January 2011 and his return for 2010/11 on 31 January 2012. Both of these returns showed a carried forward loss from...
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Adam Craggs and Constantine Christofi (RPC) review a recent tribunal decision which considers disclosure and the practical effect of Sanderson.
In J Hicks v HMRC [2018] UKFTT 22 Mr Hicks entered into a tax avoidance scheme devised by Montpelier in 2009 which had been disclosed to HMRC under the disclosure of tax avoidance schemes (DOTAS) rules. The scheme generated a loss for Mr Hicks of some £1.2m. Mr Hicks submitted his tax return for 2008/09 on 27 January 2010 which showed the loss of £1.2m as available to be carried forward and the scheme reference number (SRN) which had been allocated to the scheme by HMRC. HMRC opened an enquiry into the return on 3 December 2010.
Mr Hicks submitted his return for 2009/10 on 28 January 2011 and his return for 2010/11 on 31 January 2012. Both of these returns showed a carried forward loss from...
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