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Private client review for February

This month's private client update, by experts at Mishcon de Reya.

Allam: a lesson in business activities and investments

In A Allam [2020] UKFTT 26 (TC) the FTT had to grapple with a multitude of issues including certain procedural points related to whether the relevant enquiry notices issued by HMRC were valid in light of the taxpayer’s returns having been made in response to automated reminders. Of particular note to practitioners however are likely to be the entrepreneur’s relief and business investment relief aspects of the judgment.

Entrepreneur’s relief (ER)

The appellant (A) was together with his wife the owner of three companies Allamhouse Ltd (Allamhouse) Allam Marine Ltd (AML) and Allam Developments Ltd (ADL). Allamhouse operated as a holding company. AML carried on engineering activities the operation of Hull City Football Club (Hull City FC) and certain...

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