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Upper Tribunal Tax and Chancery Chamber
UT (Tax & Chancery) UT-2023-000031 - [2024] UKUT 00168 (TCC)
Fecha: 13-Mar-2024
Error al cargar el documento
- Heading
- Introduction
- Grounds of Appeal
- Factual findings of the FTT
- The Law
- Discussion and Analysis
- Ground 3 - the FTT erred in concluding that “the amount payable on the transfer” as found in paragraph 14A(3) Schedule 13 FA 1996 was a commercial concept ([166] and [171]), with “transfer” to be give
- Our Analysis
- Our Analysis
- In my judgment
- The principle is twofold; and it applies to the interpretation of any statutory provision
- Ground 2 – the FTT erred in concluding that it was bound by Berry v HMRC [2011] STC 1057 ([157]) given that the approach of Lewison J (as he then was) in Berry was inconsistent with the correct approa
- The Appellant’s argument
- Our Analysis
- The principles that I derive from Berry are therefore as follows
- The FTT stated at [176]
- Conclusions