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England and Wales decisions
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The Tribunal dismissed ESL’s appeal against HMRC closure notices, finding its waste-handling projects did not amount to R&D and the claimed expenditure was not proved.
The tribunal refused Mr Paul Bryan’s application to direct HMRC to issue closure notices for open income tax enquiries, finding HMRC still had reasonable grounds to continue.
The Upper Tribunal held HMRC could amend its statement of case to include a foreign dividend within the appeal’s scope and dismissed the appeal.
The Tribunal allowed an appeal against HMRC assessments, finding the disputed cash deposits were gambling winnings rather than undeclared trading income.
The Tribunal found that the Appellant was the sole shareholder during the relevant tax years, as evidenced by Companies House records and absence of contrary evidence. Therefore, all dividends were correctly assessed on him. The Discovery Assessment and Closure Notices were valid, competent, and in time. The Appellant failed to discharge the burden of proof to show the assessments were excessive or incorrect. The omissions of dividend income, benefit in kind, and HICBC were due to careless or deliberate behaviour. The penalty was validly imposed. The appeals were dismissed and assessments inc…
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The claim to carry back share losses from 2011 to 2010 was part of the 2010 return and not effectively counteracted by HMRC’s closure notice, so the self-assessment stands. The trade loss carry back claims were stand-alone claims, not part of the earlier years’ returns, and the Schedule 1A closure notice validly disallowed them.
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The Appellant did not make qualifying charitable donations in the years under appeal and admitted as much in correspondence; no evidence was provided to support the Gift Aid claims. The Closure Notices were correctly issued and the amendments to remove Gift Aid relief were correct.
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The tribunal has no jurisdiction because the consequential amendment notice is not appealable under section 31 TMA, and there was no valid claim and refusal under section 32 TMA at the time of appeal.
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The delay in appealing was serious and significant, and the appellants failed to provide a good reason for the default. The correspondence and conduct showed a focus on settlement rather than appeal, and the statutory time limits were not respected. The balance of prejudice and the public interest in finality of litigation weighed against granting permission for a late appeal.
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The appellant's appeal was struck out because the payments received via the contractor loan scheme constituted taxable employment income at the point of redirection to the trust, irrespective of subsequent loan repayment. The appellant's technical and fair trial challenges had no reasonable prospect of success, and the tribunal had no jurisdiction to consider HMRC's discretion or complaints of unfairness.
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