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	United Kingdom Upper Tribunal (Tax and Chancery Chamber)
You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> Outram & Anor v Revenue And Customs (INCOME TAX - discovery assessments) [2024] UKUT 203 (TCC) (15 July 2024) URL: http://www.bailii.org/uk/cases/UKUT/TCC/2024/203.html Cite as: [2024] BTC 523, [2024] UKUT 203 (TCC), [2024] STC 1870

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ANTHONY OUTRAM & ROSS OUTRAM v THE COMMISSIONERS FOR HIS MAJESTY'S REVENUE AND CUSTOMS [2024] UKUT 203 (TCC) (15 July 2024)

INCOME TAX - discovery assessments - Appellants had claimed losses on tax returns in relation to transactions which had been marketed as tax avoidance - agreed scheme did not achieve intended tax benefits - FTT held inaccuracies in tax returns were deliberate - Appellants appealed - held - no procedural error in review of decision by FTT, and FTT was entitled to make the amendments made to the decision - whilst FTT had purported to apply the correct subjective test when assessing whether conduct was deliberate, reasoning included an objective approach - appeal allowed and remitted to FTT