In HMRC v Lansdowne Partners Limited Partnership (Ch D – 18 October) a limited partnership carried on business as a fund manager. In August 2005 it submitted its partnership statement for 2004/05 claiming a deduction for certain ‘rebated fees’ including fees which it had reimbursed to its partners as well as to external investors. In August 2008 HMRC amended the partnership statement on the basis that the fees rebated to partners were not allowable as deductions. The partnership appealed contending firstly that it was entitled to a deduction for the fees and alternatively that HMRC’s amendment was outside the statutory time limit.
The General Commissioners accepted both these contentions and HMRC appealed to the Ch D. Lewison J held that the rebated fees did not appear to be ‘proper deductions’ as they did not appear to...
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In HMRC v Lansdowne Partners Limited Partnership (Ch D – 18 October) a limited partnership carried on business as a fund manager. In August 2005 it submitted its partnership statement for 2004/05 claiming a deduction for certain ‘rebated fees’ including fees which it had reimbursed to its partners as well as to external investors. In August 2008 HMRC amended the partnership statement on the basis that the fees rebated to partners were not allowable as deductions. The partnership appealed contending firstly that it was entitled to a deduction for the fees and alternatively that HMRC’s amendment was outside the statutory time limit.
The General Commissioners accepted both these contentions and HMRC appealed to the Ch D. Lewison J held that the rebated fees did not appear to be ‘proper deductions’ as they did not appear to...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
