Home › Forums › Patrick Cannon › What is a Type A partnership transfer under para 14 of sch 15, 2003? › Reply To: What is a Type A partnership transfer under para 14 of sch 15, 2003?
22nd July 2014 at 5:13 pm
#722
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Nick, thanks and I agree with your analysis but I would be nervous about HMRC going along with it. I guess a lot would depend upon the wording of the admission to partnership/transfer document and it might be that a little finessing would assist here.
On a separate matter you may be interested that I have already used the UT decision in Portland Gas Storage to generate an appeal in what was otherwise an out of time claim. Well done to you and Michael Thomas!