The Weekly Law Reports
[2023] 1 WLR 4216
Court of Appeal
*Civic Environmental Systems Ltd
v
Revenue and Customs Commissioners
[2023] EWCA Civ 722
2023 June 20; 26
Asplin, Simler, Nugee LJJ
Revenue— Corporation tax— Loss relief— Taxpayer company making claim to carry back losses and set them off against profits for previous tax year— Revenue giving effect to claim to carry back proportion of losses by repaying tax paid on profits for previous tax year— Revenue subsequently issuing closure notice in which profits for previous tax year revised upwards— Whether upwards revision of profits obliging revenue to give effect to taxpayer’s claim to carry back further losses—
Taxes Management Act 1970 (c 9), Sch 1A[1]
—
Income and Corporation Taxes Act 1988 (c 1), s 393A[1]
—
Finance Act 1998 (c 36), Sch 18, para 58[1]
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