The Commissioners for HM Revenue and Customs v Benham (Specialist Cars) Limited: [2017] UKUT 0389 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Warren and Judge Bishopp on 11 October 2017.
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.CORPORATION TAX – declaration under s.153A TCGA 1992 (business assets roll-over relief) ceasing to have effect – s.153A(4) providing that all necessary adjustments shall be made – whether that provides for a ‘freestanding’ power – no – whether decision notice by HMRC can be treated as discovery assessment – no – appeal dismissed.