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Upper Tribunal decides that HMRC lawfully refused late claim under Statement of Practice 5 (2001) (R (on the application of Rettig Heating Group UK Limited (in liquidation)) v HMRC)

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Published on: 13 May 2025

Published by a LexisNexis Tax expert

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Tax analysis: In R (on the application of Rettig Heating Group UK Ltd (in liquidation)) v HMRC, the Upper Tribunal (UT) decided that HMRC lawfully refused the taxpayer’s claim to set off a non-trading loan relationship deficit (NTLRD) against profits for an accounting period that ended more than 18 years before the claim was made.

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