Siri Ltd v Revenue & Customs [2011] UKFTT 794 (TC) (06 December 2011)
Siri Ltd did not receive the claimed gift aid donations, nor did it apply funds from other charities for charitable purposes. The officers of Siri Ltd acted carelessly in making false claims. HMRC's tax assessments are upheld in full.
- Citation
- [2011] UKFTT 794 (TC)
- Parties
- Appellant: Siri Ltd; Respondents: The Commissioners for Her Majesty’s Revenue and Customs
- Jurisdiction
- United Kingdom
- Judgment Date
- 06 December 2011
- Procedural Posture
- Tax Appeal / First Tier Tribunal Decision
- Outcome
- Appeal dismissed
- Legal Topics
- Gift Aid, Tax Exemptions, Charitable Expenditure, Tax Assessments, Carelessness in Tax Claims
Case Brief
Summary, issues, holding and outcome
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Parties
Siri Ltd
Appellant
The Commissioners for Her Majesty’s Revenue and Customs
Respondents
Procedural Posture
Tax Appeal / First Tier Tribunal Decision
Legal Issues
- 1 Whether gift aid donations were actually received by Siri Ltd
- 2 Whether corporation tax relief on income from other charities was properly claimed
- 3 Whether Siri Ltd's expenditure was for charitable purposes
Ratio Decidendi
Siri Ltd did not receive the claimed gift aid donations, nor did it apply funds from other charities for charitable purposes. The officers of Siri Ltd acted carelessly in making false claims. HMRC's tax assessments are upheld in full.
Court Disposition
Appeal dismissed
Orders
- All HMRC tax assessments against Siri Ltd are upheld in full
- No relief granted for gift aid or corporation tax claims
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