{"id":651900,"date":"2026-04-22T21:58:26","date_gmt":"2026-04-22T19:58:26","guid":{"rendered":"https:\/\/kohenavocats.com\/jurisprudences\/james-anderson-v-pricewaterhousecoopers-anor\/"},"modified":"2026-04-22T21:58:26","modified_gmt":"2026-04-22T19:58:26","slug":"james-anderson-v-pricewaterhousecoopers-anor","status":"publish","type":"kji_decision","link":"https:\/\/kohenavocats.com\/ru\/jurisprudences\/james-anderson-v-pricewaterhousecoopers-anor\/","title":{"rendered":"James Anderson v PriceWaterhouseCoopers & Anor"},"content":{"rendered":"
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Introduction 1. On 20 April 2022 the Tribunal (Judge Kempster) issued the following directions: Background 1. These proceedings concern a referral by Mr Anderson to the tribunal under s 12ABZB(3) of the Taxes Management Act 1970 (\u201cthe Referral\u201d). \u2026 2. I have considered correspondence from the Parties, and the Tribunal\u2019s case file generally. 3. I consider that it would be appropriate and useful to hold first a preliminary hearing to consider the following matters (which are an expansion of the points set out in the Tribunal\u2019s email dated 16 March 2022): (a) Whether the Tribunal has the power to admit a late referral. (b) Whether the Referral was made late. (c) Whether the Referral is invalid as being in substance about the amount (before sharing) of the partnership\u2019s profits or losses. This is my decision following the preliminary hearing, listed pursuant to those directions, on 30 November 2022. 2. The appellant, James Anderson (\u201cMr Anderson\u201d), was represented by David Whiscombe of Chiltern & Cambridge Consultants Limited. Imran Afzal, of counsel, appeared on behalf of the respondents, PricewaterhouseCoopers LLP (\u201cPwC\u201d) and the third party, HM Revenue and Customs (\u201cHMRC\u201d) was represented by Natasha Henshaw of its Solicitor\u2019s Office. I am most grateful for their full and helpful submissions, both written and oral. However, although carefully considered, it has not been necessary to refer to each and every argument advanced on behalf of the parties in reaching my conclusions in relation to each of the issues set out in the directions. Background Law 3. Unless otherwise stated, all subsequent statutory references are to the provisions (the material parts of which are set out in the appendix) of the Taxes Management Act 1970 (\u201cTMA\u201d). 4. A partnership may be required, under s 12AA, by notice given by HMRC to \u201cmake and deliver\u201d a partnership return. 5. Such a partnership return is required, by s 12AB(1), to include a \u201cpartnership statement\u201d showing, addition to the amount of income, loss, consideration received and tax deducted or treated as deducted from any income of the partnership, the amount, in the case of each of the partners, \u201ctaking into account any such relief or allowance, is equal to his share of that income, loss, consideration or tax.\u201d 6. Under s 12ABZB(1) a partnership return is, for tax purposes, \u201cconclusive\u201d in relation to whether a person has a share in the profits or losses of that partnership for any period and also what that person\u2019s share in those profits or losses is. 7. If there is a dispute between that person and any one or more partners of the partnership as to whether what is stated in the partnership return is correct, it may be referred to the Tribunal for determination under s 12ABZB(3). 8. Section 12ABZB(5) provides that such a referral \u201cmust\u201d be made before the \u201cend of the period of 12 months\u201d beginning with the day after the day on which the partnership return was \u201cdelivered\u201d or, (which is not applicable in the present case) if the return was amended, within 12 months from the day after the day the amendment was made. 9. However, s 12ABZB(4) provides that a referral under s 12ABZB(3) does not include a dispute \u201cto the extent that is in substance about the amount (before sharing) of the partnership\u2019s profits or losses for a period. Facts 10. Before considering the issues, and to put them in context, I have summarised the circumstances in which they arose. However, I should make it clear that what follows is solely for this purpose and anything I say should not be taken as a finding of fact in relation to any further proceedings in this matter. 11. Mr Anderson was a partner in PwC from 1 July 2016. In May 2018 he was told that the decision had been taken to serve notice requiring his compulsory retirement. Although, under the terms of the LLP agreement Mr Anderson was entitled to be given six months\u2019 notice of termination, he retired from PwC on 30 November 2018. 12. Mr Anderson claimed that in requiring him to retire, PwC had had unlawfully discriminated against him by reason of a pre-existing medical condition which had been aggravated by their actions. The claim was settled on the basis of a payment by PwC to Mr Anderson comprising two distinct elements: (1) a payment described as \u201cthe balance of profit share\u201d for the period 1 July 2018 to 30 November 2018; and (2) a payment described as \u201can additional payment of an amount equal to 12 months\u2019 profit share\u201d (the \u201cAdditional Payment\u201d). 13. Both elements were included as profit share allocated to Mr Anderson in the partnership return for the accounting period from 1 July 2018 to 30 June 2019 which was filed by PwC on 26 October 2020 (the \u201cPartnership Return\u201d). 14. While he accepts that the first element was correctly treated as a share of profit chargeable to income tax, Mr Anderson contends that the Additional Payment was compensation in settlement of his claim for damages which should not have been included as a share of profit allocated to him in the Partnership Return. Paragraph 5 of the Referral states: \u201c5. It is not disputed that the first element is correctly treated as a share of profit chargeable to Income Tax. However, JA [Mr Anderson] considers that the Additional Payment is not as a matter of fact a share of profit but compensation in settlement of his damages claim; and that he is not liable to pay Income Tax in respect of it.\u201d 15. Mr Anderson became aware of how the Additional Payment had been treated on receipt of an email from PwC, dated 5 January 2021. This stated that the details of his profit share were available and that the computation had been finalised and submitted to HMRC. 16. On 10 December 2021 Mr Anderson made the Referral, under s 12ABZB(3), to the Tribunal. Although Mr Anderson now contends that the Referral was made in time it included an application for an extension of time for its admission. The Issues 17. I now turn to the issues. Power to admit late referral 18. It is common ground that there is no provision within the Taxes Management Act 1970 (\u201cTMA\u201d) under which the Tribunal may extend the time in which a referral under s 12ABZB(3) can be made. It is therefore necessary to consider whether there is any other provision under which the Tribunal may do so. 19. On an appeal from the Social Entitlement Chamber of the First-tier Tribunal in VK v HMRC [2016] UKUT 331 (AAC) (\u201cVK\u201d) the Administrative Appeals Chamber of the Upper Tribunal (Judge Jacobs, Judge Wikeley and Judge Mitchell) observed, at [2], that legislative provisions that confer authority to extend time do not have to be contained in an Act but may also be contained in secondary legislation: \u201c\u2026 if its enabling powers permit such provision to be made.\u201d The Upper Tribunal continued, at [3], noting that paragraph 4 of Schedule 5 to the Tribunals Courts and Enforcement Act 2007 (\u201cTCEA\u201d): \u201c\u2026 properly interpreted, authorised rules of tribunal procedure to confer power on the First-tier Tribunal to extend time.. 20. The authorised rules of procedure in the Tax Chamber of the First-tier Tribunal are the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 of which the rule 21 provides: (1) Where an enactment provides for a person or persons to make an originating application or reference to the Tribunal, the appellant must start proceedings by providing an application notice or notice of reference to the Tribunal within any time limit imposed by that enactment. (2) \u2026 [not applicable] (3) If the appellant provides the application notice or notice of reference to the Tribunal later than the time required by paragraph (1) or by any extension of time under rule 5(3)(a) (power to extend time)\u2014 (a) the application notice or notice of reference must include a request for an extension of time and the reason why the application notice or notice of reference was not provided in time; and (b) unless the Tribunal extends time for the application notice or notice of reference under rule 5(3)(a) (power to extend time) the Tribunal must not admit the application notice or notice of reference. (3A) The power of the Tribunal under these Rules to extend time for starting proceedings shall not apply in a CAA case. (4) When the Tribunal receives an application notice or a notice of reference it must send a copy of the notice and any accompanying document to any respondent. 21. Rule 5(1), which deals with the Tribunal\u2019s case management powers, provides that, subject to the provisions of the TCEA \u201cand any other enactment\u201d, the Tribunal may regulate its own procedure. 22. Rule 5(3)(a), to which rule 21(3) refers, provides that the Tribunal \u201cmay by direction\u201d: extend or shorten the time for complying with any rule, practice direction or direction, unless such extension or shortening would conflict with a provision of another enactment setting down a time limit; \u2026 23. Therefore, the starting point is that a referral under s 12ABZB(3) \u201cmust not\u201d be admitted unless it is either within the time limit imposed by s 12ABZB(5) which, for present purposes, is the \u201cend of the period of 12 months\u201d beginning with the day after the day on which the partnership return was \u201cdelivered\u201d or the Tribunal, if it is able to do so, extends the time for it to be admitted under rule 5(3)(a). 24. Although the parties agree that the Tribunal may extend the time for complying with a statutory time limit, either as an extension of time under rule 21 or an extension of the statutory time limit as envisaged in VK (see paragraph 19, above), they part company in relation to whether it has the power to grant such an extension in the case of a referral under s 12ABZB(5) and whether such an extension would conflict with a provision of another enactment. 25. Mr Whiscombe, for Mr Anderson, raised the argument that as the time limit was contained in the TMA, \u201canother enactment\u201d must refer to a statute other than the TMA. In the absence of any provision in another statute he contends that there is nothing to preclude an extension of time being granted by the Tribunal under rule 5(3)(a). 26. Mr Afzal, for PwC, contends that the reference to \u201canother enactment\u201d in rule 5(3)(a) refers to an enactment other than the Procedure Rules and that, as such, there is a conflict with the time limit in s 12ABZB(5) with the result that the Tribunal does not have the power to grant an extension of time for a referral under s 12ABZB(3). Ms Henshaw, for HMRC, agrees with Mr Afzal that an extension of time is precluded but contends that the reference to \u201canother enactment\u201d is a reference to the TCEA. 27. Given the reference to the TCEA and \u201cany other enactment\u201d in rule 5(1), I consider Ms Henshaw\u2019s to be the better construction of rule 5(3)(a) and agree with her that the reference to \u201canother enactment\u201d is to the TCEA. However, for present purposes, it does not matter whether the other enactment is in fact the Procedure Rules or the TCEA as in both cases it would appear that the Tribunal is precluded from extending the time for a reference under s 12ABZB(3). 28. However, the Upper Tribunal in VK, having considered rule 21(3) of the Tax Chamber Procedure Rules (which it set out in full), noted, albeit obiter, that: \u201c43. There is some jarring here with the wording of rule 5(3)(a), which ostensibly prevents an extension of time if that would conflict with an enactment setting a time limit. But the specific provision for extending time in rule 21 must have been intended to operate as an exception to the rule 5(3)(a) restriction.\u201d 29. Mr Whiscombe contends that, although obiter, the approach in VK should be adopted in the present case with the effect that the Tribunal may extend the time limit in rule 21 \u201cas an exception to the rule 5(3)(a) restriction. 30. However, I do not agree. As Mr Afzal submits, not only is the view expressed by the Upper Tribunal, which is not supported by any reasoning, obiter and therefore not binding, rule 5(3)(a) and rule 21 are silent as to the existence of any exception. Moreover, if the Upper Tribunal in VK were right it would render the restriction in rule 5(3)(a), \u201cunless such extension \u2026 would conflict with the provision of another enactment setting down a time limit\u201d otiose. 31. It therefore follows that as an extension of time would conflict with a provision of another enactment, namely s 12ABZB(5), the Tribunal does not have the power under rule 5(3)(a) to grant an extension of time to make a referral under s 12ABZB(3) with the result that any referral that is not made in time \u201cmust not\u201d be admitted. Whether Referral late 32. It is not disputed that the partnership return was submitted to HMRC on 26 October 2020 and that the Referral was made, more than 12 months later, on 10 December 2021. 33. Although accompanied by an application for an extension of time when it was made, Mr Whiscombe now contends that the Referral was in fact made within the s 12ABZB(5) time limit of \u201c12 months beginning with the day after the day on which the partnership return was delivered\u201d and, as such, an extension of time is not required. Neither Mr Afzal nor Ms Henshaw agree. 34. In essence this issue concerns the interpretation of s 12ABZB(5), in particular to whom the partnership return is to be \u201cdelivered\u201d pursuant to paragraph (a) of that subsection. 35. Mr Afzal, with whom Ms Henshaw agrees, says it is HMRC whereas Mr Whiscombe, who accepts that delivery to HMRC is the most obvious interpretation of s 12ABZB(5), contends that time runs from when the partnership statement, which is required by s 12AB(1) to be included with a partnership return, is delivered to the individual partner making the referral under s 12ABZB(3). 36. Mr Whiscombe points out that as there is no statutory obligation on a partnership to notify each partner of the amount of taxable profit allocated to him or her it is possible that the time for making a referral under s 12ABZB(3) could already have started running or may even have expired before a partner is aware of a dispute to be referred to the Tribunal. Such a situation could arise through error or carelessness by a partnership that fails to timeously provide the individual partners details of their profit allocations. It could, Mr Whiscombe argues, even be abused by a partnership where a partner has left in acrimonious circumstances. He contends that such issues would not arise if his construction of s 12ABZB were to be adopted. He does concede, however, that to construe s 12ABZN(5) as meaning delivery of the partnership statement to the partner making the referral does requires \u201csome gymnastics\u201d. 37. Given that Mr Anderson first became aware of his partnership allocation on 5 January 2001 the effect of such an interpretation in the present case would be that the Referral, on 20 December 2021, was made within 12 months from the day after the day the partnership statement was delivered to him and no extension of time is required for it to be admitted. 38. However, rather then engage in the gymnastics required for Mr Whiscombe\u2019s construction of s 12ABZB, I prefer that advanced by PwC and HMRC (which Mr Whiscombe also accepts as being the more natural and obvious interpretation) that the use of \u201cdelivered\u201d in s 12ABZB(5) refers to the partnership return being delivered to HMRC. Such a construction is, in my judgment, clearly consistent with the TMA provisions regarding the filing of a partnership tax return. 39. For example, where a partnership is required by a notice issued by an \u201cofficer of the Board\u201d of HMRC under s 12AA to \u201cmake and deliver\u201d a partnership return, s 12AA(2) requires that partnership return to be delivered to that \u201cofficer\u201d, ie it must be delivered to HMRC. It therefore follows that the phrase used in s 12ABZB(5) \u201cthe day on which the partnership return was delivered\u201d must refer to the day on which it was delivered to HMRC. 40. Additionally, although s 12AB(1) provides that a partnership return \u201cshall include\u201d a partnership statement\u201d, s 12ABZB(5) expressly refers to the delivery of a \u201cpartnership return\u201d not a \u201cpartnership statement\u201d. In my judgment, had s 12ABZB(5) been intended to refer to a \u201cpartnership statement\u201d as opposed to a \u201cpartnership return\u201d it would have said so. Also, given the reference to both a \u201cpartnership return\u201d and \u201cpartnership statement\u201d in the legislation the two terms cannot be interchangeable or one mean the other. Had that been intended it would not have been necessary for the legislation to refer to both. 41. Accordingly, as it was made on 10 December 2021, more than 12 months after the partnership return was delivered to HMRC on 26 October 2020, the Referral cannot have been made before the end of the period of 12 months beginning with the day after the day on which the partnership return was delivered as required by s 12ABZB(5). Whether Referral invalid 42. In essence this issue concerns whether the dispute between the parties was \u201cin substance\u201d about the nature of the Additional Payment, ie whether it was a profit share (as contended by PwC) or compensation (as contended by Mr Anderson), or about the amount (before sharing) of the partnership\u2019s profits. 43. Mr Whiscombe says that the dispute is essentially about the nature of the Additional Payment. However, he accepts that, as payment of compensation is an expense deductible in computing profit, it does have a \u201cknock on\u201d effect on the amount of partnership profits. Mr Afzal, with whom Ms Henshaw agrees, contends that because of that effect on the amount of partnership profits the dispute is, in substance, directly about the amount of partnership profits. 44. Although initially attracted by the argument advanced by Mr Whiscombe, on balance, given the potential effect of any determination by the Tribunal on the partnerships profit, I agree with Mr Afzal that the dispute is, in substance, about the amount of the partnership\u2019s profits whether directly, as PwC and HMRC contend, or indirectly, as Mr Whiscombe accepts. This is apparent from the description of the dispute at paragraph 5 of the Referral itself (see paragraph 14, above) from which the issue to be determined by the Tribunal if the Referral were to be admitted is whether the Additional payment is as \u201ca matter of fact a share of profit\u201d. 45. Accordingly the Tribunal is precluded from admitted the Referral, which is \u201cin substance\u201d about the amount of the partnerships profits, by s 12ABZB(4). conclusion 46. For the reasons above I have concluded that: (1) The Tribunal does not have the power to admit an referral out of time; (2) The Referral was made out of time; and (3) The Referral is invalid as being in substance about the amount (before sharing) of the partnership\u2019s profits or losses. Right to apply for permission to appeal 47. This document contains full findings of fact and reasons for the decision. Any party dissatisfied with this decision has a right to apply for permission to appeal against it pursuant to Rule 39 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009. The application must be received by this Tribunal not later than 56 days after this decision is sent to that party. The parties are referred to \u201cGuidance to accompany a Decision from the First-tier Tribunal (Tax Chamber)\u201d which accompanies and forms part of this decision notice. JOHN BROOKS TRIBUNAL JUDGE Release date: 06 DECEMBER 2022<\/p>\n<\/div>\n

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Sources officielles :<\/strong> consulter la page source<\/a><\/p>\n

Open Justice Licence (The National Archives).<\/em><\/p>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

Introduction 1. On 20 April 2022 the Tribunal (Judge Kempster) issued the following directions: Background 1. These proceedings concern a referral by Mr Anderson to the tribunal under s 12ABZB(3) of the Taxes Management Act 1970 (\u201cthe Referral\u201d). \u2026 2. I have considered correspondence from the Parties, and the Tribunal\u2019s case file generally. 3. I consider that it would be…<\/p>\n","protected":false},"featured_media":0,"template":"","meta":{"_crdt_document":""},"kji_country":[7608],"kji_court":[7915],"kji_chamber":[],"kji_year":[32183],"kji_subject":[7612],"kji_keyword":[7903,10971,25650,10888,7636],"kji_language":[7611],"class_list":["post-651900","kji_decision","type-kji_decision","status-publish","hentry","kji_country-royaume-uni","kji_court-first-tier-tribunal-tax-chamber","kji_year-32183","kji_subject-fiscal","kji_keyword-notice","kji_keyword-partnership","kji_keyword-referral","kji_keyword-return","kji_keyword-tribunal","kji_language-anglais"],"yoast_head":"\nJames Anderson v PriceWaterhouseCoopers & Anor - Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/kohenavocats.com\/ru\/jurisprudences\/james-anderson-v-pricewaterhousecoopers-anor\/\" \/>\n<meta property=\"og:locale\" content=\"ru_RU\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"James Anderson v PriceWaterhouseCoopers & Anor\" \/>\n<meta property=\"og:description\" content=\"Introduction 1. On 20 April 2022 the Tribunal (Judge Kempster) issued the following directions: Background 1. These proceedings concern a referral by Mr Anderson to the tribunal under s 12ABZB(3) of the Taxes Management Act 1970 (\u201cthe Referral\u201d). \u2026 2. I have considered correspondence from the Parties, and the Tribunal\u2019s case file generally. 3. 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On 20 April 2022 the Tribunal (Judge Kempster) issued the following directions: Background 1. These proceedings concern a referral by Mr Anderson to the tribunal under s 12ABZB(3) of the Taxes Management Act 1970 (\u201cthe Referral\u201d). \u2026 2. I have considered correspondence from the Parties, and the Tribunal\u2019s case file generally. 3. 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