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J Anderson v HMRC

Trade or investment?

In J Anderson v HMRC [2016] UKFTT 565 (10 August 2016) the FTT found that a football agent’s involvement with a football academy did not amount to a trade.

Mr Anderson claimed losses of £3 002 772 in his personal income tax return. HMRC considered that these losses arising from activities undertaken to develop and bring young South African footballing talent to the European football market were not allowable (ITA 2007 s 66 and s 74).

Mr Anderson had invested the amount claimed in a South African soccer academy Bafana having borrowed the amount from a Jersey based entity Maddox.

The FTT found that Mr Anderson had not established that the time recorded in his logs was spent seriously pursuing core profit making activities relating only to the Bafana Scheme. It also found that Mr Anderson’s actual input into the activities...

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