Nicholas Powell v The Commissioners for HMRC

JudgeGILL HUNTER
Judgment Date09 May 2025
Neutral Citation[2025] UKFTT 528 (TC)
Year2025
CourtFirst-tier Tribunal (Tax Chamber)
CounselMr Scott Redpath Of Counsel,For
Date09 May 2025
Neutral Citation: [2025] UKFTT 00528 (TC)
Case Number: TC09518
FIRST-TIER TRIBUNAL
TAX CHAMBER
Taylor House, London
Appeal reference: TC/2024/00354
INCOME TAXsection 415 Income Tax (Trading and Other Income) Act 2005 - whether,
pursuant to deed of novation, there had been a release or repayment of participator loan –
appeal REFUSED
Heard on: 29 and 30 April 2025
Judgment date: 9 May 2025
Before
TRIBUNAL JUDGE AMANDA BROWN KC
GILL HUNTER
Between
NICHOLAS POWELL
Appellant
and
THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS
Respondents
Representation:
For the Appellant:Mr Scott Redpath of Counsel instructed by Hazelwoods LLP
For the Respondents: Miss Sarah Marsden litigator of HM Revenue and Customs’
Solicitor’s Office

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