Liability of a company to corporation tax under s.6(1) Income and Corporation Taxes Act 1988 was not relieved by the failure of the proper officer to perform the duty imposed by s.108 Tax Management Act 1970. The deeming provision contained in s.739(2) of the 1988 Act had effect only for the purposes of the Income Tax Acts and had no impact on potential liability to corporation tax. * Leave to appeal to the House of Lords granted.

CA (Lord Hope, Lord Millett, Lord Hope)

10/10/2000