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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
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.
The appellant’s reliance on others, and in particular his accountants and AML is not a ground of appeal which falls within the tribunal’s jurisdiction. If Mr Brown believes that he was misled by his advisers, then it is for him to take action against those advisers.
It is for the appellant to show that the closure notice overcharges him, and he has produced no evidence that such is the case.
Accordingly, the appellant’s grounds of appeal are not within the jurisdiction of the tribunal and thus his appeal should be automatically struck out. Alternatively, the appellant’s case has no reasonable prospect of success and should be struck out on that basis.
- 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