As readers will be aware, the Government decided to include provisions in this year’s Finance Act that require businesses to account for profits that they do not actually make, when they appropriate trading stock for non-trading purposes.
The history behind this statutory provision can be simply stated. For the past 50 years, the Revenue have found the House of Lords’ decision in Sharkey (HM Inspector of Taxes) v Wernher, as Arthur Daley would have said, “a nice little earner”.
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