• Service: Tax, Global Indirect Tax, International Executive Services, International Tax
  • Type: Regulatory update
  • Date: 8/30/2013

United Kingdom - Evidence of expenditure lacking (capital gains tax) 

August 30:  A UK court dismissed a taxpayer’s appeal of an assessment for capital gains tax for gain realised on the disposal of two properties because the taxpayer failed to provide evidence substantiating his claims for an increased basis for improvements made to the properties. Ridpath v. HMRC, TC/2012/07297 (12 February 2013)

The taxpayer disputed the capital gains tax calculations, and appealed on the basis that £40,000 had been spent on property improvements and thus was deductible in the tax computation. The taxpayer confirmed that internal capital renovation works were made at the properties, but had a poor recollection of the exact works to each property. He provided bank statements to show that an expenditure was incurred, but there was no evidence of who the payee was or the nature of the expenditure.

The First Tier Tribunal accepted that it was very likely that part of the expenditure from the taxpayer’s bank account (some £128,000) was incurred as an expenditure on the properties; however, the taxpayer was unable to point to a single item and explain by way of illustration how the money leaving his account had been spent. The First Tier Tribunal thus dismissed the appeal. Read the decision: Ridpath [PDF 83 KB]

Also discussed in this KPMG report are the following topics:

  • Relaxation to ISA rules - Inheritance tax implications and interaction with other reliefs
  • VAT - Rapid sequence limited
  • Non-statutory clearance guidance

©2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.

The KPMG logo and name are trademarks of KPMG International.

KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever.

The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

Direct comments, including requests for subscriptions, to
For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at:

+ 1 202 533 4366

1801 K Street NW
Washington, DC 20006.


Share this

Share this


Subscribe to receive the latest TaxNewsFlash email alerts (you must select the option for TaxNewsFlash)

Already a Subscriber? Login

Not a member? Subscribe now