TC09518 - [2025] UKFTT 00528 (TC)

Case Number: TC09518

Taylor House, London

Appeal reference: TC/2024/00354

INCOME TAX – section 415 Income Tax (Trading and Other Income) Act 2005 - whether, pursuant to deed of novation, there had been a release or repayment of participator loan – appeal REFUSED

Judgment date: 9 May 2025

Before

TRIBUNAL JUDGE AMANDA BROWN KC

GILL HUNTER

Between

NICHOLAS POWELL

Appellant

and

THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Respondents

Representation:

For the Appellant: Mr Scott Redpath of Counsel instructed by Hazelwoods LLP

For the Respondents: Miss Sarah Marsden litigator of HM Revenue and Customs’ Solicitor’s Office

DECISION