- UT rules on construction of closure notices (Daarasp LLP and Betex LLP)
- Why it matters
- Case details
Tax analysis: In Daarasp LLP and Betex LLP, the Upper Tribunal (UT) ruled that HMRC was entitled to argue that the taxpayers did not qualify for capital allowances, and that it was not precluded from doing so by the terms of its closure notices. While the closure notices stated that an unquantifiable part of the taxpayers’ claim ‘may be allowable’, it was not tenable in the circumstances to construe this as meaning that HMRC would not rely on any argument that would reduce the available allowances to nil.
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