- The case concerns a taxpayer’s claim for Bad Debt Relief (BDR) and their unsuccessful attempts to appeal a decision at the FTT and UT.
- Previous litigation involving BT and GMAC established that claims for supplies prior to 1 April 1989 are out of time, but the taxpayer argued that there are still factual and legal issues to be considered.
- The FTT concluded that the appeal had no reasonable prospect of success and struck it out, a decision which was upheld by the UT and dismissed in the taxpayer’s subsequent appeal.
Source KPMG
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