1) Kieran Looney; 2) Kieran Looney and Associates (a firm) v The Commissioners for HM Revenue and Customs: [2020] UKUT 0119 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Raghavan and Judge Greenbank on 22 April 2020.
Read the full decision in .
Tax treatment of certain payments under management training contract – whether FTT erred in conclusion termination payment trading revenue receipt (consideration for cancellation of the contract to provide training) rather than capital (compensation for loss of a secret process in proprietary performance management system) - House of Lords’ decision in Evans Medical Supplies Ltd v Moriarty (H M Inspector of Taxes) ([1957] 37 TC 540) considered – no – whether FTT erred in conclusion other contractual payments gave rise to tax liability on appellant (as opposed, through a multi-party agreement, to other entities appellant owned) – no – appeal dismissed.