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ARTICLE · 14 APRIL 2021

Outram – Tribunal Prevents HMRC From Relying On New Argument

Reynolds Porter Chamberlain
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In Outram and another v HMRC [2021] UKFTT 29 (TC) the First-tier Tribunal (FTT) prevented HMRC from relying on a new argument contained in its skeleton argument which had not been included...

United KingdomLitigation, Mediation & Arbitration
Constantine Christofi
Constantine Christofi

In Outram and another v HMRC [2021] UKFTT 29 (TC) the First-tier Tribunal (FTT) prevented HMRC from relying on a new argument contained in its skeleton argument which had not been included in its statement of case.

Background

This was a case management decision relating to appeals by two taxpayers, Anthony and Ross Outram (the Applicants) concerning their participation in a Montpelier tax mitigation arrangement (the Scheme). 

In February 2015, HMRC issued discovery assessments, pursuant to section 29, Taxes Management Act 1970, to the Applicants in relation to their 2005/06 tax returns, which included trading losses they claimed had been generated as a consequence of their participation in the Scheme. The time limit for HMRC to enquire into the returns had expired. 

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