HMRC wins another sideways loss relief case (Thomson, Worsfold & Mungavin v HMRC)

Table of contents

• What are the practical implications of this case?
• What was the background?
• What did the Tribunal decide?
• Trading question
• Commerciality question
• Penalties
• Case details

Article summary

Tax analysis: The First-tier Tax Tribunal (FTT) has found against the taxpayers on all grounds relating to the substantive question of whether sideways loss relief was available on losses arising in an avoidance scheme involving contracts for difference (CFDs). Two of the taxpayers succeeded in reducing the associated penalty somewhat.