HMRC ASSESSMENT POWERS CURBED BY FTT

摘要

The Upper Tribunal (UT) in Revenue and Customs v Benham (Specialist Cars) Ltd [2017] UKUT 389 has allowed an appeal against the FTT decision in Benham (Specialist Cars) Ltd [2016] UKFTT 330 finding that Taxation of Chargeable Gains Act 1992 (TCGA 1992), s153A (4) does not give HMRC free-standing powers to tax chargeable gains, following the expiry of a declaration of intention to roll over the gains for which no actual claim for roll-over relief was made.