KEVIN JOHN PITT v THE COMMISSIONERS FOR HIS MAJESTY鈥橲 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 鈥� Penalty under s208 Finance Act 2014 issued after issue of follower notice in relation to arrangements said to give rise to loss on 鈥渞elevant discounted securities鈥� (Schedule 13 Finance Act 1996) 鈥� whether FTT erred in its approach to holding judicial ruling (Audley v HMRC) was 鈥渞elevant鈥� to taxpayer鈥檚 arrangements because it had regard to 鈥減ost-Ramsay analysis鈥� facts rather than primary facts 鈥� no 鈥� appeal dismissed
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Published 24 January 2024