ANTHONY OUTRAM & ROSS OUTRAM v THE COMMISSIONERS FOR HIS MAJESTY바카라 사이트™S REVENUE AND CUSTOMS [2024] UKUT 00203 (TCC)
Upper Tribunal Tax & Chancery decision of Judge Jeanette Zaman and Judge Ashley Greenbank on July 12th 2024
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INCOME TAX 바카라 사이트“ discovery assessments 바카라 사이트“ Appellants had claimed losses on tax returns in relation to transactions which had been marketed as tax avoidance 바카라 사이트“ agreed scheme did not achieve intended tax benefits 바카라 사이트“ FTT held inaccuracies in tax returns were deliberate 바카라 사이트“ Appellants appealed 바카라 사이트“ held 바카라 사이트“ no procedural error in review of decision by FTT, and FTT was entitled to make the amendments made to the decision 바카라 사이트“ whilst FTT had purported to apply the correct subjective test when assessing whether conduct was deliberate, reasoning included an objective approach 바카라 사이트“ appeal allowed and remitted to FTT