The Queen (on the application of M Carlton and others) v CRC, Queen’s Bench Division, 30 January 2018
Application for judicial review of partner payment notices
The taxpayers were members of partnerships that invested in commercial property to take advantage of business premises renovation allowances (BPRA) (CAA 2001, s 360A et seq). They claimed loss relief in their tax returns.
HMRC opened enquiries into two of the partnerships and issued partner payment notices (PPNs) to the taxpayers. They sought judicial review of the notices. They said there was no evidence that their purpose in entering into the arrangements had been to obtain a tax advantage. Therefore, FA 2014, Sch 32 para 3 ...