Siri Ltd v Revenue & Customs [2011] UKFTT 794 (TC) (06 December 2011)

Siri Ltd v Revenue & Customs [2011] UKFTT 794 (TC) (06 December 2011)

Siri Ltd did not receive the claimed donations, and thus was not entitled to gift aid relief. The evidence did not support that funds from other charities were used for charitable purposes, so corporation tax relief was also not available. The officers of Siri acted carelessly in making the claims, justifying HMRC's assessments within the statutory time limits. The appeal was dismissed and all assessments upheld.

Citation
[2011] UKFTT 794
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, Corporation Tax, Charitable Expenditure, Tax Exemptions, Tax Assessments
Tax Law Charity Law Gift Aid Corporation Tax Charitable Expenditure Tax Exemptions Tax Assessments

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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. 1 Whether Siri Ltd received donations qualifying for gift aid relief
  2. 2 Whether Siri Ltd was entitled to corporation tax relief on income from other charities
  3. 3 Whether Siri Ltd's expenditure was for charitable purposes

Ratio Decidendi

Siri Ltd did not receive the claimed donations, and thus was not entitled to gift aid relief. The evidence did not support that funds from other charities were used for charitable purposes, so corporation tax relief was also not available. The officers of Siri acted carelessly in making the claims, justifying HMRC's assessments within the statutory time limits. The appeal was dismissed and all assessments upheld.

Court Disposition

Appeal dismissed

Orders

  • All HMRC assessments to recover gift aid relief and disallow corporation tax relief upheld in full