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Lost cause

14 April 2011
Issue: 4301 / Categories: Tax cases , Income Tax
Ronald Farrell (TC1051)

The appeal concerned the liability of the appellant to income tax at the dividend upper rate which arose on interest he received from UK banks and a building society during the tax year 2007/08.

He argued that in comparison with the rule applicable to the body of taxpayers generally he would be discriminated against unfairly if he were required to include his bank and building society interest in his return.

The appellant had failed to include interest earned in his 2007/08 tax return contending that he was not obliged to do so on the following basis:

  • there was no mechanism for recovering higher rate tax on interest from taxpayers who did not fall within the list of people to whom HMRC said they would send tax returns;
  • the only reason he had been sent a...

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