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) >> Assem Allam v Revenue and Customs [2021] UKUT 291 (TCC) (23 November 2021)
URL: http://www.bailii.org/uk/cases/UKUT/TCC/2021/291.html
Cite as: [2021] STI 2797, [2021] UKUT 291 (TCC), [2021] BTC 549, [2022] STC 37

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Assem Allam v Revenue and Customs [2021] UKUT 291 (TCC) (23 November 2021)

ROCEDURE - automated notices requiring returns - effect of s103 Finance Act 2020 - effect of s12D TMA 1970 - validity of notices of enquiry under s9A TMA 1970 CAPITAL GAINS TAX - entrepreneurs' relief - s165A(3) TCGA 1992 - company involved in property development and investment property - nature and extent of activities - whether a trading company INCOME TAX - remittance basis - business investment relief - whether dividend left outstanding on loan account correctly treated as an investment INCOME TAX - transactions in securities - whether main purpose or one of the main purposes of person being a party was to obtain an income tax advantage

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