TC09615 - [2025] UKFTT 01016 (TC)

Fecha: 31-Jul-2025

The GAAP Issue

The GAAP Issue

69.

As noted above, attached to all Closure Notices were profit and loss accounts for the Breeding Activity; these included opening and closing stock valuations for each of the horses which HMRC considered fell within that Activity.

70.

HMRC’s position was that Mr Tinkler had incorrectly valued his opening and closing stock when calculating his trading profits; that this GAAP Issue was within the scope of the Closure Notices and should be decided by the Tribunal at the substantive hearing. Mr Waldegrave expanded the points made in the SoC as follows:

(1)

If HMRC won on their primary case, only the horses within the Breeding Activity would be relevant;

(2)

if HMRC lost on their primary case, but won on the Wholly and Exclusively Issue, all horses would be relevant; and

(3)

HMRC would then need to carry out a valuation exercise to calculate the correct stock value of each horse for each accounting period, and not simply those within the Breeding Activity.