United Kingdom Upper Tribunal (Tax and Chancery Chamber)

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You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> Revenue & Customs v Hamilton & Kinneil (Archerfield) Ltd & Ors [2015] UKUT 130 (TCC) (20 March 2015)
URL: http://www.bailii.org/uk/cases/UKUT/TCC/2015/130.html
Cite as: [2015] UKUT 130 (TCC), [2015] STC 1852, [2015] BTC 512

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Revenue & Customs v Hamilton & Kinneil (Archerfield) Ltd & Ors [2015] UKUT 130 (TCC) (20 March 2015)

INCOME TAX /CORPORATION TAX - Losses – interpretation of s118ZC ICTA 1988 limit on loss relief for members of LLPs - whether appellant’s third share in capital of LLP was “contributed” as capital (s118ZC(3) ICTA) on basis that this was the amount appellant had exposed to risk– no - whether appellant’s third share was included in amount the appellant was “liable to contribute” to the assets of the LLP in the event LLP was wound up (s118Z(4)(a) ICTA) – no - appeal from Tax Chamber allowed

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