APPEAL OF JURISDICTIONAL DECISION ON CLOSURE NOTICES DISMISSED

摘要

In the case of Spring Salmon & Seafood Ltd v Revenue and Customs Commissioners [2014] UKUT 0488 (TCC), Spring Salmon & Seafood Ltd (SSS) appealed part of the decision of the FTT (SSS Ltd v Revenue & Customs [2013] UKFTT 320 (TC)) concerning its jurisdiction in relation to closure notice amendments. These denied terminal loss relief following enquiries into SSS's 2002 and 2003 corporation tax returns. Closure notices were issued for 2002, 2003, 2004 and 2005. Firstly, the FTT considered whether it had jurisdiction to determine if a contract settlement entered into in 2004 included liabilities relating to the 2002 and 2003 tax years so as to constitute 'tax paid' in respect of those years, or not.