Tensions between transparency and privacy and some recent tribunal decisions are reviewed by Clare Wilson and Edward Reed (Macfarlanes).
PPR relief: the importance of evidence
In last month’s column we considered the FTT’s decision in Ives v HMRC [2023] UKFTT 986 (TC). There the taxpayer argued successfully that PPR relief applied in respect of the sale of three properties in relatively quick succession each at a substantial gain thanks largely to the extensive evidence put forward to support the taxpayer’s assertion that all three properties had been used by him as family homes.
This month the impact of the absence of evidence re-emphasises the point in a complementary decision relating to PPR relief this time a taxpayer loss. In S Patwary v HMRC [2024] UKFTT 53 (TC) the taxpayer appealed against a closure notice issued by HMRC disallowing a PPR relief claim...
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Tensions between transparency and privacy and some recent tribunal decisions are reviewed by Clare Wilson and Edward Reed (Macfarlanes).
PPR relief: the importance of evidence
In last month’s column we considered the FTT’s decision in Ives v HMRC [2023] UKFTT 986 (TC). There the taxpayer argued successfully that PPR relief applied in respect of the sale of three properties in relatively quick succession each at a substantial gain thanks largely to the extensive evidence put forward to support the taxpayer’s assertion that all three properties had been used by him as family homes.
This month the impact of the absence of evidence re-emphasises the point in a complementary decision relating to PPR relief this time a taxpayer loss. In S Patwary v HMRC [2024] UKFTT 53 (TC) the taxpayer appealed against a closure notice issued by HMRC disallowing a PPR relief claim...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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