Scambler and another v Revenue and Customs Commissioners

Income tax – Loss relief. The Upper Tribunal (Tax and Chancery Chamber) (the tribunal) dismissed the appeal by the taxpayer dairy farmers against a decision of the First-tier Tribunal (Tax Chamber) which had dismissed the taxpayers' appeals against amendments to their self-assessment tax returns due to restrictions on 'sideways loss relief' contained in s 67 of the Income Tax Act 2007. The tribunal accepted that the taxpayers had not satisfied the 'reasonable expectation of profits test' set out in s 68(3) of that Act and therefore, sideways loss relief had not been available to them for the year at issue.

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