Robert Ames v The Commissioners for HM Revenue and Customs: [2018] UKUT 0190 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Fancourt and Judge Sinfield on 25 June 2018.

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CAPITAL GAINS TAX 鈥� Enterprise Investment Scheme 鈥� meaning of 鈥渁ttributable鈥� in section 150A(2) Taxation of Chargeable Gains Act 1992 鈥搘hether CGT exemption only available if EIS income tax relief claimed - JUDICIAL REVIEW 鈥� whether HMRC adopted flawed methodology in appraising taxpayer鈥檚 late claim for relief and exercising powers under section 5(1) Commissioners for Revenue and Customs Act 2005 鈥� whether HMRC acted with conspicuous unfairness.

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Published 27 June 2018