KEVIN JOHN PITT v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2024] UKUT 00021 (TCC)
| Jurisdiction | UK Non-devolved |
| Judge | JUDGE SWAMI RAGHAVAN,JUDGE JENNIFER DEAN on |
| Court | Upper Tribunal (Tax and Chancery Chamber) |
| Published date | 24 January 2024 |
Neutral Citation: [2024] UKUT 00021 (TCC) Case Number: UT/2022/000120
UPPER TRIBUNAL
(Tax and Chancery Chamber) Rolls Building, London
INCOME TAX – Penalty under s208 Finance Act 2014 issued after issue of follower notice in
relation to arrangements said to give rise to loss on “relevant discounted securities” (Schedule
13 Finance Act 1996) – whether FTT erred in its approach to holding judicial ruling (Audley
v HMRC) was “relevant” to taxpayer’s arrangements because it had regard to “post-Ramsay
analysis” facts rather than primary facts – no – appeal dismissed
Heard on: 11 December 2023
Judgment date: 22 January 2024
Before
JUDGE SWAMI RAGHAVAN
JUDGE JENNIFER DEAN
Between
KEVIN JOHN PITT Appellant
and
THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS
Respondents
Representation:
For the Appellant: Michael Avient, Counsel, instructed by Price Bailey LLP
For the Respondents: Nicholas Macklam, Counsel, instructed by the General Counsel and
Solicitor to His Majesty’s Revenue and Customs
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