The WLR Daily case summaries
[2011] WLR (D) 154
Revenue— Corporation tax— Capital allowances— Self assessment— — Closure notice issued disallowing claim— — Partnership appealing— — Revenue raising issues not mentioned in closure— — Whether revenue only able to rely on issues raised in closure notice— — Transactions carried out to obtain fiscal advantage— — Limited partnerships entering into software licence agreements— — Consideration for licences funded by non-recourse loans to members of partnership— — Loans provided by software vendor company itself through series of circular transactions— — Whether loans expended on acquisition of software rights— — Whether partnerships entitled to first-year allowances—
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Taxes Management Act 1970 (c 9), s 28B (as inserted by Finance Act 2001 (c 9) s 88, Sch 29)
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Capital Allowances Act 2001 (c 2), s 45 (as amended by sections 165 and 166 of the Finance Act 2003)