![TC09660 - [2025] UKFTT 01226 (TC)](https://backend.juristeca.com/files/emisores/logo_7HSuEAV.png){kind=logo}
DISCUSSION
DISCUSSION
Submissions
In summary Mr Brown submitted as follows:
It was HMRC who suggested that he should appeal against the closure notice. So, it now seems wrong that they are suggesting that he has no grounds for that appeal. If they thought he had no grounds for appeal, then why did they offer him the opportunity to appeal in the first place.
- Heading
- INTRODUCTION
- THE EVIDENCE AND THE FACTS
- DISCUSSION
- There is no justification for HMRC saying that the tribunal has no jurisdiction in relation to his appeal
- The Rangers decision was released after the tax year under consideration
- The loan was repaid and thus there is no liability to tax on it
- The effect of the decision in RFC 2012 plc (formerly the Rangers Football Club plc) v Advocate General for Scotland [2017] UKSC 45 (“ Rangers ”) is that the payments made by the employer to the trust
- The decision in Hoey v HMRC [2022] EWCA Civ 656 (“ Hoey ”) is authority for the proposition that this tribunal has no jurisdiction to consider HMRC’s discretion to impose any tax on Mr Brown rather th
- There is no justification in the complaints made about the statutory review process which was undertaken wholly properly The application of the loan charge legislation is not relevant to this appeal
- My view
- Conclusions