Les Howard reports of a recent tribunal case complicated by a Transfer of Going Concern (TOGC).
The First Tier Tax Tribunal (FTT) heard an interesting case where two taxpayers were co-joined parties; one having transferred its business to the other. The reality of the TOGC meant that HMRC were able to assess the transferor company even though its observations were made on the transferee company. The Tribunal decision brings together a number of important legal and procedural point.
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