In John Henderson v HMRC [2015] UKFTT 584 (25 November 2015) the FTT found that the losses made by a farmer could not be set off against his rental income.
Mr Henderson carried out general farming activities but had done so at a loss over several tax years. His income was supplemented by rental income paid under a lease of part of his farm so that the tenant could quarry the land and excavate gravel. The issue was whether the farming losses could be claimed:
generally if the rental income was part of his farming/trade income; or
if it was not then ‘sideways’ against the rental income under ITA 2007 s 64.
The FTT explained that under ITTOIA 2005 ss 12 and 335 profits arising from land in respect of certain concerns...
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In John Henderson v HMRC [2015] UKFTT 584 (25 November 2015) the FTT found that the losses made by a farmer could not be set off against his rental income.
Mr Henderson carried out general farming activities but had done so at a loss over several tax years. His income was supplemented by rental income paid under a lease of part of his farm so that the tenant could quarry the land and excavate gravel. The issue was whether the farming losses could be claimed:
generally if the rental income was part of his farming/trade income; or
if it was not then ‘sideways’ against the rental income under ITA 2007 s 64.
The FTT explained that under ITTOIA 2005 ss 12 and 335 profits arising from land in respect of certain concerns...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
