TC09613 - [2025] UKFTT 00989 (TC)

Case Number: TC09613

Taylor House, London

Appeal reference: TC/2023/08843

INCOME TAX – purported assignment of interests in partnership profits – whether purported assignor remained entitled to those profits – section 8 Income Tax (Trading and Other Income) Act 2005 – yes – appeal dismissed

Heard on: 9-10 June 2025

Written submissions: 18 July and1 and 4 August 2025

Judgment date: 14 August 2025

Before

TRIBUNAL JUDGE MARK BALDWIN

MR JOHN AGBOOLA JP

Between

CRAIG WILLIAM BURLEY

Appellant

and

THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Respondents

Representation:

For the Appellant: Patrick Cannon of counsel, instructed on a direct access basis

For the Respondents: Edward Waldegrave of counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs

DECISION