Knibbs and others v Revenue and Customs Commissioners

Income tax – Loss relief. The Revenue and Customs Commissioners (HMRC) had been entitled to open enquiries, under s 9A of the Taxes Management Act 1970, into the claimant taxpayers' Year 2 tax returns to establish the validity of their claims for relief from income tax. The claimants had sought to carry back losses incurred, in many cases, as partners in various film partnerships. The Companies Court, applying R (on the application of De Silva and another) v Revenue and Customs Commissioners[2017] All ER (D) 108 (Nov), struck out the claimants' claims for, among other things, declarations requiring the HMRC to give immediate effect to their tax claims.

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