Legal News

Court of Appeal confirms appointment of receivers prevented group relief (Farnborough v HMRC)

Court of Appeal confirms appointment of receivers prevented group relief (Farnborough v HMRC)
Published on: 11 February 2019
Published by: LexisPSL
  • Court of Appeal confirms appointment of receivers prevented group relief (Farnborough v HMRC)
  • What are the practical implications of this case?
  • What was the background?
  • Taxpayers’ grounds of appeal
  • HMRC’s counter-arguments
  • What did the court decide?
  • Receivers’ appointment caused shareholder to lose control of PH2L
  • Receivership constituted arrangements
  • Case details

Article summary

Tax analysis: The Court of Appeal dismissed the taxpayers’ appeal, upholding the decision of the Upper Tribunal (UT) that the company in receivership was unable to surrender losses to the appellant taxpayers by way of group relief because the receiver’s appointment severed the company in receivership from the loss relief group. or take a trial to read the full analysis.

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