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Equine losses generally

Tax Planning for Farm and Land Diversification

Julie Butler (FCA)
Bloomsbury Professional
Publication Date:
Law Stated At:
11 July 2023
Chapter 12: Hobby and lifestyle farming and use of farming losses Partnership loss manipulation – ‘sideways’ loss claims True commerciality Losses to be offset against gains (possible farm development gains) Losses in the limited company – group loss relief Restriction of loss relief for individuals with a non-active trade – 25% relief restriction Sideways loss relief – Revenue & Customs Brief 2 March 2007 Duality of purpose and personal benefit The French case The Erridge case Losses and the diversified activity Naghshineh v HMRC – 17 years of loss allowed The benefit of the expert witness HMRC v Naghshineh – overturned in the Upper Tribunal Naghshineh – UT overturn confirmed in the Court of Appeal Pragmatic strategy around loss claim Temporary carry-back of losses ...

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