Jurisprudência do Upper Tribunal (Tax and Chancery Chamber)
Acórdãos do Upper Tribunal (Tax and Chancery Chamber) com resumo em linguagem simples, tese jurídica e perguntas frequentes. O conteúdo original é público e oficial; os resumos e análises são produzidos pela tecnologia do VadeLab.
Upper Tribunal Upholds Refusal for Late Tax Appeals, Emphasising Tribunal's Discretion
The Upper Tribunal has refused a taxpayer's request to appeal a decision that stopped them from making late tax appeals. The First-tier Tribunal had decided that the taxpayer's appeals against HMRC's tax calculations and penalties were too late. The Upper Tribunal agreed, stating that the First-tier Tribunal had the right to make that decision and didn't make a legal mistake, even though the rules for late appeals changed after the initial decision.
Understanding Corporation Tax Deductions: When Payments to a National Agency Aren't Allowable
The Upper Tribunal recently looked at a company's attempt to reduce its corporation tax bill by deducting a large payment made to a national asset management agency. The company argued this payment should count as a business expense under 'loan relationship rules' or as a cost to improve an asset. However, the Tribunal decided against the company, agreeing with HMRC that the payment was mainly for the benefit of a larger group of businesses, not just the company itself, and therefore couldn't be deducted for tax.