Dalla Jenney and Chris Bates of Norton Rose LLP consider the recent High Court judgment in the Tower MCashback case
Dalla Jenney and Chris Bates of Norton Rose LLP consider the recent High Court judgment in the Tower MCashback case
Summary
In a robust judgment allowing the taxpayer's appeal Henderson J overturned the decision of the Special Commissioners in Tower MCashback LLP1 and another v HMRC[2008] EWHC 2387 (Ch). The decision addressed two important questions. The substantive question was to what extent a limited liability partnership had incurred expenditure qualifying for a first-year capital allowance on the acquisition of a software licence. The procedural question was whether HMRC can introduce new grounds for denying...
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Dalla Jenney and Chris Bates of Norton Rose LLP consider the recent High Court judgment in the Tower MCashback case
Dalla Jenney and Chris Bates of Norton Rose LLP consider the recent High Court judgment in the Tower MCashback case
Summary
In a robust judgment allowing the taxpayer's appeal Henderson J overturned the decision of the Special Commissioners in Tower MCashback LLP1 and another v HMRC[2008] EWHC 2387 (Ch). The decision addressed two important questions. The substantive question was to what extent a limited liability partnership had incurred expenditure qualifying for a first-year capital allowance on the acquisition of a software licence. The procedural question was whether HMRC can introduce new grounds for denying...
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