In Judith Thorne v HMRC (TC03851 – 30 July 2014) the FTT found that losses realised in an equestrian business were not available for set-off against other income.
In her self-assessment return Ms Thorne had elected to set-off losses realised in her ‘equestrian breeder and farming’ business against her employment income (TTA 2007 s 64(1) (2)). HMRC had denied the claim on the ground that the business was not carried on on a commercial basis with a view to profit.
The business which owned four horses had suffered badly from the injury of its star horse which had been promised to competition at the international level. The business had then embarked on a new asparagus trade which was not expected to yield profits for three years. The claim for loss relief related to the business as a whole.
The FTT found that...
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In Judith Thorne v HMRC (TC03851 – 30 July 2014) the FTT found that losses realised in an equestrian business were not available for set-off against other income.
In her self-assessment return Ms Thorne had elected to set-off losses realised in her ‘equestrian breeder and farming’ business against her employment income (TTA 2007 s 64(1) (2)). HMRC had denied the claim on the ground that the business was not carried on on a commercial basis with a view to profit.
The business which owned four horses had suffered badly from the injury of its star horse which had been promised to competition at the international level. The business had then embarked on a new asparagus trade which was not expected to yield profits for three years. The claim for loss relief related to the business as a whole.
The FTT found that...
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