It may seem surprising that HMRC was granted leave to appeal to the Supreme Court when it lost every argument at each step of the way there. There are however several other cases standing behind HMRC v NCL Investments Ltd and another [2022] UKSC 9 and large sums are riding on the outcome from the Crown’s perspective.
The Supreme Court unanimously dismissed HMRC’s appeal. The Court of Appeal the Upper Tribunal and the FTT had also rejected HMRC’s arguments and concluded that the taxpayers (which were the employing companies) were entitled to a deduction as a trading expense in respect of the accounting...
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It may seem surprising that HMRC was granted leave to appeal to the Supreme Court when it lost every argument at each step of the way there. There are however several other cases standing behind HMRC v NCL Investments Ltd and another [2022] UKSC 9 and large sums are riding on the outcome from the Crown’s perspective.
The Supreme Court unanimously dismissed HMRC’s appeal. The Court of Appeal the Upper Tribunal and the FTT had also rejected HMRC’s arguments and concluded that the taxpayers (which were the employing companies) were entitled to a deduction as a trading expense in respect of the accounting...
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