InSpring Salmon & Seafood v HMRC[2015] UKFTT 616 (30 November 2015) the FTT found that the company had made a valid claim in its tax return so that the closure notice issued by HMRC was effective in denying it.
Spring Salmon was entitled to intangibles relief in respect of goodwill acquired in July 2002. The company claimed terminal loss relief (‘the claim’) affecting the 2004 period and the 2005 period. If the claim was made in the 2004 or the 2005 return it was accepted that the closure notices were effective to deny the relief. If the claim was not made in a return it was also agreed that any enquiry should have been opened under TMA 1970 Sch 1A so that the closure notices were ineffective to deny relief.
In...
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InSpring Salmon & Seafood v HMRC[2015] UKFTT 616 (30 November 2015) the FTT found that the company had made a valid claim in its tax return so that the closure notice issued by HMRC was effective in denying it.
Spring Salmon was entitled to intangibles relief in respect of goodwill acquired in July 2002. The company claimed terminal loss relief (‘the claim’) affecting the 2004 period and the 2005 period. If the claim was made in the 2004 or the 2005 return it was accepted that the closure notices were effective to deny the relief. If the claim was not made in a return it was also agreed that any enquiry should have been opened under TMA 1970 Sch 1A so that the closure notices were ineffective to deny relief.
In...
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