Grint v Revenue and Customs (INCOME TAX/CORPORATION TAX : Other) [2016] UKFTT 537 (TC) (03 August 2016)

Grint v Revenue and Customs (INCOME TAX/CORPORATION TAX : Other) [2016] UKFTT 537 (TC) (03 August 2016)

The appellant did not meet the statutory criteria for a change in accounting date under s 217 ITTOIA because the period of account ending with the new accounting date exceeded 18 months, and the New Accounts were not adopted at the relevant time. The Schedule and Return Accounts, although purporting to be accounts, were not reliable representations of past transactions and did not satisfy the statutory requirements.

Citation
[2016] UKFTT 537 (TC)
Parties
Appellant: Rupert Grint; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
Jurisdiction
United Kingdom
Judgment Date
03 August 2016
Procedural Posture
Tax Appeal / First Tier Tribunal Decision
Outcome
Appeal dismissed
Legal Topics
Income Tax, Change of Accounting Date, Basis Period, Section 217 ITTOIA, Definition of Accounts
Tax Law Income Tax Change of Accounting Date Basis Period Section 217 ITTOIA Definition of Accounts

Case Brief

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Parties

Rupert Grint

Appellant

The Commissioners for Her Majesty’s Revenue & Customs

Respondents

Procedural Posture

Tax Appeal / First Tier Tribunal Decision

Legal Issues

  1. 1 Whether the appellant met the criteria in s 217 ITTOIA for a change in accounting date
  2. 2 Meaning of 'accounts' under tax legislation
  3. 3 Whether various financial statements constituted 'accounts' for the purposes of the 18 month test

Ratio Decidendi

The appellant did not meet the statutory criteria for a change in accounting date under s 217 ITTOIA because the period of account ending with the new accounting date exceeded 18 months, and the New Accounts were not adopted at the relevant time. The Schedule and Return Accounts, although purporting to be accounts, were not reliable representations of past transactions and did not satisfy the statutory requirements.

Court Disposition

Appeal dismissed

Orders

  • No change in accounting date for tax purposes
  • Tax liability remains as determined by HMRC