This site uses cookies. By continuing to browse the site you are agreeing to our use of cookies. To find out more about cookies on this website and how to delete cookies, see our privacy notice.

First-tier Tribunal did not have jurisdiction to consider validity of PPN in a penalty appeal

By Mark McLaughlin, July 2020

A payment made in consideration for the cancellation of a contract to provide training was an income (as opposed to a capital) receipt and the First-tier Tribunal made no material errors in its conclusions. 

The second appellant (KLA) carried on the trade of business coaching from 1 October 2003 until the partnership dissolved on 22 December 2009. The partners of KLA were the first appellant (KL) and a company (RC); KL and his wife were director shareholders of RC. KLA entered into a 36-month agreement with a customer (T) to provide management training for T’s senior management on 14 January 2009. 

The agreement between KLA and T provided (among other things) that the training would be discontinued on the service of a termination notice by T and the payment of an early termination fee. The relevant

Subscribe to the McLaughlin’s Tax Case Library to get instant access
to the Tax Case Library.
14 day free trial , 90 day money back guarantee
Subscribe

Related or similar articles

First-tier Tribunal did not have jurisdiction to consider validity of PPN in a penalty appeal
By Mark McLaughlin, July 2020
Assessments of additional income relating to suppressed takings confirmed
By Mark McLaughlin, April 2020
Film and video production LLPs were not trading
By Mark McLaughlin, November 2019
Expenditure On Rights To Income From Films Was Capital
By Mark McLaughlin, October 2017
Payment To Settle Litigation Was Not Wholly And Exclusively For The Trade
By Mark McLaughlin, April 2016