Assem Allam v The Commissioners for HM Revenue and Customs [2021] UKUT 0291 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Edwin Johnson and Judge Jonathan Cannan on 23 November 2021
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PROCEDURE 鈥� automated notices requiring returns 鈥� effect of s103 Finance Act 2020 鈥� effect of s12D TMA 1970 鈥� validity of notices of enquiry under s9A TMA 1970 CAPITAL GAINS TAX 鈥� entrepreneurs鈥� relief 鈥� s165A(3) TCGA 1992 鈥� company involved in property development and investment property 鈥� nature and extent of activities 鈥� whether a trading company INCOME TAX 鈥� remittance basis 鈥� business investment relief 鈥� whether dividend left outstanding on loan account correctly treated as an investment INCOME TAX 鈥� transactions in securities 鈥� whether main purpose or one of the main purposes of person being a party was to obtain an income tax advantage