Jade Hall examines Ultrapolymers Ltd, the first decision looking at whether a taxpayer has satisfied the conditions to obtain automatic permission to opt to tax
There has been considerable commentary and case law regarding the option to tax including the notification process but the rules associated with the permission to opt to tax is a little discussed area. There have been plenty of cases where a party (whether the taxpayer or HMRC) has tried to argue that an option to tax was not valid because it was not notified to HMRC in writing but it seems that very few cases (if any until recently) have been based on not seeking HMRC's permission to opt to tax in advance. The First Tier Tribunal decision of Ultrapolymers Ltd (TC00324) seems to be the first of its kind looking into whether a taxpayer has satisfied the conditions to obtain automatic...
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Jade Hall examines Ultrapolymers Ltd, the first decision looking at whether a taxpayer has satisfied the conditions to obtain automatic permission to opt to tax
There has been considerable commentary and case law regarding the option to tax including the notification process but the rules associated with the permission to opt to tax is a little discussed area. There have been plenty of cases where a party (whether the taxpayer or HMRC) has tried to argue that an option to tax was not valid because it was not notified to HMRC in writing but it seems that very few cases (if any until recently) have been based on not seeking HMRC's permission to opt to tax in advance. The First Tier Tribunal decision of Ultrapolymers Ltd (TC00324) seems to be the first of its kind looking into whether a taxpayer has satisfied the conditions to obtain automatic...
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:
