- Court of Appeal upholds UT decision that a debit was entirely attributable to an unallowable purpose (Fidex v HMRC)
- Original News
- What happened in this case?
- Why does it matter?
Tax analysis: The Court of Appeal (CA) has dismissed the taxpayer’s appeal against the Upper Tribunal (UT) decision, confirming that (i) the jurisdiction of the First-tier Tax Tribunal (FTT) extended to being able to consider an HMRC argument, based on the application of the loan relationships unallowable purposes rule (at the relevant time, found in paragraph 13 of Schedule 9 to the Finance Act 1996 (FA 1996)), not originally included in a closure notice and (ii) in Fidex’ case, the entirety of a debit brought into account was attributable to its unallowable purpose, with the consequence that it was fully disallowed.
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