The First-tier Tribunal has recently handed down its judgment in The Vaccine Research Ltd Partnership and another (TC9476) where it found that licence fees received as part of a scheme intended to generate income tax losses were not income and so not subject to income tax.
How did we get here?
HMRC had issued tax assessments for the years ending 5 April 2007 2014 and 2015.
The appeal relating to the first year of assessment had been subject to a First-tier Tribunal decision in December 2012 and a subsequent Upper Tribunal decision in September 2014.
The matters relating to all years were then heard by the First-tier Tribunal in October 2019 however the parties were advised that there was no realistic prospect of a decision being reached and therefore in March 2022 the First-tier Tribunal suggested that the appeals be re-heard by a new panel.
The...
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