KEVIN JOHN PITT v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2024] UKUT 00021 (TCC)
Upper Tribunal Tax and Chancery decision of JUDGE SWAMI RAGHAVAN and JUDGE JENNIFER DEAN on 22 January 2024
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INCOME TAX – Penalty under s208 Finance Act 2014 issued after issue of follower notice in relation to arrangements said to give rise to loss on “relevant discounted securities” (Schedule 13 Finance Act 1996) – whether FTT erred in its approach to holding judicial ruling (Audley v HMRC) was “relevant” to taxpayer’s arrangements because it had regard to “post-Ramsay analysis” facts rather than primary facts – no – appeal dismissed
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Published 24 January 2024