Evidence
Evidence
The Tribunal was provided with a Bundle of Documents, which contained:
the Closure Notices;
Mr Tinkler’s grounds of appeal;
the SoC; and
the Application, the Response, the Reply and the Tribunal’s related directions and correspondence.
The morning before the hearing, Mr Waldegrave provided the Tribunal and Mr Gordon with a copy of an HMRC letter to Mr Tinkler dated 20 November 2019. On the day of the hearing, he emailed:
notes of a meeting between Mr Tinkler and HMRC, which had taken place on 30 April 2014;
Mr Tinkler’s letter of appeal to HMRC dated 12 September 2022; and
HMRC’s statutory review decision.
Mr Gordon did not object to those documents being considered by the Tribunal and I admitted them into evidence.
- Heading
- Introduction
- Evidence
- The Closure Notices
- Closure Notice for 2010-11
- Closure Notice for 2011-12
- Closure Notice for 2012-13
- Closure Notice for 2013-14
- Closure Notices for 2014-15 and 2015-16
- The Statement of Case
- The Application and the Response
- The Scope of this hearing
- Preliminary issue
- The legislation
- Tower MCashback
- Fidex
- Investec
- The Section 66 Issue
- The parties’ submissions
- Discussion and conclusions
- The GAAP Issue
- Lower of cost and NRV
- Submissions and my view
- The year 2013-14
- Permission to amend grounds
- Conclusions
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