In Standfast Corporate Underwriters v HMRC (TC03322 – 12 February 2014) the tribunal considered the eligibility for group relief of underwriting losses of a corporate underwriter at Lloyd’s.
The tribunal explained that the special scheme of taxation which applies to underwriters – and which takes into account the fact that the profit and losses of a particular period may not be known for a few years after the end of the period – gave rise to potential abuse. A loss making company could be shut down and transferred into a profitable group before the losses were recognised for tax purposes so that the losses would be available for group relief. FA 1994 s 227A is aimed at such tax avoidance.
The tribunal found that s 227A could apply to losses incurred in the underwriting year 2000 which had been postponed by an election...
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In Standfast Corporate Underwriters v HMRC (TC03322 – 12 February 2014) the tribunal considered the eligibility for group relief of underwriting losses of a corporate underwriter at Lloyd’s.
The tribunal explained that the special scheme of taxation which applies to underwriters – and which takes into account the fact that the profit and losses of a particular period may not be known for a few years after the end of the period – gave rise to potential abuse. A loss making company could be shut down and transferred into a profitable group before the losses were recognised for tax purposes so that the losses would be available for group relief. FA 1994 s 227A is aimed at such tax avoidance.
The tribunal found that s 227A could apply to losses incurred in the underwriting year 2000 which had been postponed by an election...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
