Non-domiciles and remittance basis of taxation: In A Alimahomed v HMRC [2024] UKFTT 432 (TC) (23 May 2024) the FTT allowed part of the taxpayer’s appeal finding that a discovery assessment in relation to the 2015/16 tax year was not valid because the issue of deliberate omission (under one limb of TMA 1970 s 29(4)) was not substantiated by HMRC. The FTT further found that it was insufficient for HMRC to simply say that the pleadings may have been over-prescribed in an attempt to depart from the original case pleaded in the absence of any application to amend the pleadings.
However the FTT agreed with HMRC’s closure notice in relation to the 2016/17 tax year that the appellant had made various taxable remittances (since the remittances were initiated by the appellant even if he did not personally benefit from them) with the FTT concluding (at...
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Non-domiciles and remittance basis of taxation: In A Alimahomed v HMRC [2024] UKFTT 432 (TC) (23 May 2024) the FTT allowed part of the taxpayer’s appeal finding that a discovery assessment in relation to the 2015/16 tax year was not valid because the issue of deliberate omission (under one limb of TMA 1970 s 29(4)) was not substantiated by HMRC. The FTT further found that it was insufficient for HMRC to simply say that the pleadings may have been over-prescribed in an attempt to depart from the original case pleaded in the absence of any application to amend the pleadings.
However the FTT agreed with HMRC’s closure notice in relation to the 2016/17 tax year that the appellant had made various taxable remittances (since the remittances were initiated by the appellant even if he did not personally benefit from them) with the FTT concluding (at...
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