Shinelock fails to extract pounds of tax relief from HMRC. David Whiscombe (BKL) reviews a case on loan relationships with some intriguing procedural issues.
Although the basic facts in Shinelock Ltd v HMRC [2021] UKFTT 320 (TC) were not very complicated and the amount of tax at stake was modest the case raises questions both of technical and of procedural interest.
Possibly the most notable point is the finding that HMRC may in some circumstances be regarded as having agreed to extend the time limit for making a claim without having intended to do so or indeed without having knowingly considered the matter at all.
The facts of the case
Shinelock a company owned by Mr Ahmed bought a property in 2009 for £725 000. The purchase was financed partly by bank loan and partly by amounts paid by Mr Ahmed. Some five years later...
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Shinelock fails to extract pounds of tax relief from HMRC. David Whiscombe (BKL) reviews a case on loan relationships with some intriguing procedural issues.
Although the basic facts in Shinelock Ltd v HMRC [2021] UKFTT 320 (TC) were not very complicated and the amount of tax at stake was modest the case raises questions both of technical and of procedural interest.
Possibly the most notable point is the finding that HMRC may in some circumstances be regarded as having agreed to extend the time limit for making a claim without having intended to do so or indeed without having knowingly considered the matter at all.
The facts of the case
Shinelock a company owned by Mr Ahmed bought a property in 2009 for £725 000. The purchase was financed partly by bank loan and partly by amounts paid by Mr Ahmed. Some five years later...
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:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")