I have a copy of a note from Standard Life provided by a client. Note deals with appeal to the FTT. Taxpayer made a chageable event gain in excess of £100,000 and lost her PAs for the year because the full gain was added by HMRC to determine the total income. This had a detrimental effect on the calculation of the top slicing relief. Taxpayer appealed. Judge ruled that the averaging regulations should apply to determine the sum to be include as income giving a much lower figure for the purposes of restricting the PAs. This is (and in many cases will be) beneficial for the taxpayer. In this case it will save the lady £20,000+. Interesting to see HMRC's reaction.
Any thoughts? Anyone else seen anything on this? Subject to not breaching copywrite (can't think that will apply) I am happy to provide a PDF file copy of the note from Standard Life.