Appointment of receiver prevented group relief (Farnborough v HMRC)

Table of contents

• Original news
• What was this case about?
• What did the tribunal decide?
• Arrangements
• Control
• Statutory interpretation
• What should tax lawyers take note of?

Article summary

Tax analysis: The First-tier Tax Tribunal (FTT) dismissed the taxpayers’ appeal against HMRC’s decision that a company in receivership was unable to surrender losses to them by way of group relief because the receiver’s appointment severed the company from the loss relief group.