Tax

G4S Cash Solutions (UK) Ltd v Revenue and Customs (INCOME TAX/CORPORATION TAX : Other)

[2016] UKFTT TC TC05015First-tier Tribunal (Tax)2016

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Corporation Tax � parking fines � whether allowable deduction in computing profits to be charged to corporation tax � held no � appeal refused

Chris Stone, Counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs, for the Respondents

(i) an appeal of two discovery assessments issued by HMRC in respect of the corporation tax computation for the accounting periods ending 31 December 2007 and 31 December 2008 in the sums of �158,170.20 and �157,711.28 plus interest; and

(ii) an appeal in respect of two closure notices issued by HMRC in respect of the appellant�s accounting periods ended 31 December 2009 and 31 December 2010.� Those closure notices amended the appellant�s returns by �124,679.24 and �139,667.08 respectively.

The amounts assessed by those assessments and notices represent the additional corporation tax payable if amounts accrued in the appellant�s accounts for those periods in respect of penalty charge notices (parking fines or �PCNs�) and deducted in computing its profits for corporation tax purpose are, as HMRC assert, not deductible under

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