The Commissioners for HM Revenue and Customs v Hamilton and Kinneil (Archerfield) Limited and Others: [2015] UKUT 0130 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Warren on 20 March 2015.
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INCOME TAX /CORPORATION TAX - Losses 鈥� interpretation of s118ZC ICTA 1988 limit on loss relief for members of LLPs - whether appellant鈥檚 third share in capital of LLP was 鈥渃ontributed鈥� as capital (s118ZC(3) ICTA) on basis that this was the amount appellant had exposed to risk鈥� no - whether appellant鈥檚 third share was included in amount the appellant was 鈥渓iable to contribute鈥� to the assets of the LLP in the event LLP was wound up (s118Z(4)(a) ICTA) 鈥� no - appeal from Tax Chamber allowed.
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Published 1 December 2016