- published: 11 Apr 2017
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HM Revenue and Customs
Her Majesty's Revenue and Customs (HM Revenue and Customs or HMRC) is a non-ministerial department of the UK Government responsible for the collection of taxes, the payment of some forms of state support, and the administration of other regulatory regimes including the national minimum wage.
HMRC was formed by the merger of the Inland Revenue and Her Majesty's Customs and Excise which took effect on 18 April 2005. The department's logo is the St Edward's Crown enclosed within a circle.
Departmental responsibilities
The department is responsible for the administration and collection of direct taxes including income tax and corporation tax, capital taxes such as capital gains tax and inheritance tax, indirect taxes (including value added tax), excise duties and stamp duty land tax, and environmental taxes such as Air Passenger Duty and the climate change levy. Other aspects of the department's responsibilities include National Insurance contributions, the distribution of child benefit and some other forms of state support including the Child Trust Fund, payments of Tax Credits, enforcement of the national minimum wage, administering anti-money laundering registrations for Money Service Businesses and collection and publication of the trade-in-goods statistics. Responsibility for the protection of the UK's borders passed to UK Visas and Immigration the of UK Border Agency within the Home Office on 1 April 2008 and then to UK Visas and Immigration in 2013.
This page contains text from Wikipedia, the Free Encyclopedia - https://wn.com/HM_Revenue_and_Customs
Her Majesty
Her Majesty may refer to:
See also
This page contains text from Wikipedia, the Free Encyclopedia - https://wn.com/Her_Majesty
Her Majesty the Decemberists
Her Majesty the Decemberists is the second full-length album by The Decemberists, released on September 9, 2003, by Kill Rock Stars. The song "Song for Myla Goldberg" was written years earlier, after Colin Meloy had been a media escort for the novelist Myla Goldberg during a tour following the publication of her first book, Bee Season. "The Bachelor and the Bride" has the words "stripped bare" in the chorus, and appears to be a reference to Marcel Duchamp's piece "The Bride Stripped Bare by Her Bachelors, Even".
The album cover was designed by the Portland artist Carson Ellis, the long-time girlfriend (and now wife) of Meloy, who has created artwork for each of the band's albums.
Track listing
All songs written by Colin Meloy.
Note: On some editions, the track listing printed on the actual disc omits "The Chimbley Sweep", though the song is listed on the back of the CD jacket and in the liner notes.
Personnel
According to the liner notes of Her Majesty the Decemberists.
This page contains text from Wikipedia, the Free Encyclopedia - https://wn.com/Her_Majesty_the_Decemberists
Her Majesty (song)
"Her Majesty" is a song written by Paul McCartney (although credited to Lennon–McCartney) that appears on the Beatles' album Abbey Road. It is a brief tongue-in-cheek music hall song. "Her Majesty" is the final track of the album and appears 14 seconds after the song "The End", but was not listed on the original sleeve. As such, it is considered one of the first examples of a hidden track in rock music.
The song is notably one of the few tracks by the Beatles to directly refer to Queen Elizabeth II, the others being "Penny Lane" (released as a single and later included on the U.S. Magical Mystery Tour album) and "Mean Mr. Mustard" (also from Abbey Road).
Recording
The song was recorded in three takes on 2 July 1969, prior to the Beatles beginning work on "Golden Slumbers/Carry That Weight". McCartney sang and simultaneously played a fingerstyle acoustic guitar accompaniment. The decision to exclude it from the Abbey Road medley was made on 30 July.
The song runs only 23 seconds, but the Beatles also recorded a longer version of the song during the "Get Back" sessions.
This page contains text from Wikipedia, the Free Encyclopedia - https://wn.com/Her_Majesty_(song)
Podcasts:
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The Commissioners for Her Majesty's Revenue and Customs v The Investment Trust Companies
[2017] UKSC 29 UKSC 2015/0057 The Commissioners for Her Majesty's Revenue and Customs (Appellants) v The Investment Trust Companies (in liquidation) (Respondents) UKSC 2015/0058 The Commissioners for Her Majesty's Revenue and Customs (Respondents) v The Investment Trust Companies (in liquidation) (Appellants) On appeal from the Court of Appeal (Civil Division) (England and Wales) This case concerns a claim in unjust enrichment following mistaken payment of VAT. The nine claimants in this case The Investment Trust Companies, ("the ITCS") are closed-ended investment funds constituted as limited companies. Between 1992 and 2002 they received supplies of investment management services from their investment managers ("the Managers"). It was generally understood that these services did no...
published: 11 Apr 2017 -
Anson v Commissioners for Her Majesty's Revenue and Customs
[2015] UKSC 44 UKSC 2013/0068 Anson (Appellant) v Commissioners for Her Majesty's Revenue and Customs (Respondent) On appeal from the Court of Appeal (Civil Division) (England and Wales) The appellant is a member of a Delaware limited liability company, whose members pay tax in the United States on their share of the company's profits. The appellant remitted all of his share of the company's profits to the UK (net of US taxes). The appellant was liable to pay UK tax only on income remitted to the UK, but that included his shares of the profits of the company for the period 6 April 1997 to 5 April 2004 ("the relevant period"), unless any double tax relief or domestic unilateral relief was available. HMRC decided that the appellant was not entitled to double tax relief and sought to levy...
published: 01 Jul 2015 -
Commissioners for Her Majesty's Revenue and Customs v Pendragon plc and other
[2015] UKSC 37 UKSC 2013/0197 Commissioners for Her Majesty's Revenue and Customs (Appellant) v Pendragon plc and others (Respondents) On appeal from the Court of Appeal (Civil Division) (England and Wales) This appeal concerned the application of the European law principle of abuse of rights in the context of VAT. The respondents are members of the Pendragon group, the largest car sales group in Europe. In 2000 and in 2001, Pendragon implemented arrangements which by reference to the strict application of the relevant legislation resulted in a substantial VAT advantage. The Commissioners challenged the scheme as being abusive on the basis that the arrangements resulted in a taxing outcome contrary to the purpose of the legislation in circumstances in which that outcome was the intenti...
published: 10 Jun 2015 -
Commissioners for Her Majesty's Revenue and Customs v The Rank Group PLC
[2015] UKSC 48 UKSC 2013/0257 Commissioners for Her Majesty's Revenue and Customs (Respondent) v The Rank Group PLC (Appellant) On appeal from the Court of Appeal (Civil Division) (England and Wales) This appeal considered whether the element of chance in a slot machine connected to a detached random number generator (RNG) which is used by several such machines is 'provided by means of the machine'. The appellant, Rank Group, is a gaming business. One type of slot machine they use is hooked up to a central RNG servicing several slot machines, instead of having an individual RNG inside each slot machine. If, notwithstanding this physical separation, the element of chance is provided 'by means of the machine', in the words of the relevant legislation, they will be liable to VAT on the t...
published: 08 Jul 2015 -
Routier and another (Appellants) v Commissioners for Her Majesty's Revenue and Customs (Respondent)
[2019] UKSC 43 UKSC 2017/0190 Routier and another (Appellants) v Commissioners for Her Majesty's Revenue and Customs (Respondent) On appeal from the Court of Appeal Civil Division (England and Wales) On 9 October 2007 Mrs Beryl Coulter died in Jersey, and by her will she left her residuary estate on trust for either the building of homes for the elderly of the parish, or to an organisation called Jersey Hospice Care. Her will was drafted to be governed by the law of Jersey. Her executors (the Appellants) considered that the gift should be exempted from inheritance tax under s. 23 of the Inheritance Tax Act 1984 as it was for charitable purposes. HMRC however disagreed, and determined that the gift was liable to inheritance tax of approximately £600,000. The executors appealed this ...
published: 16 Oct 2019 -
Commissioners for Her Majesty’s Revenue and Customs (Appellant) v Tooth (Respondent)
UKSC 2019/0136 On appeal from the Court of Appeal Civil Division (England and Wales) Mr Tooth entered into an arrangement to obtain an employment loss (“Romangate”). Whether or not the arrangement achieved its objective at the time it was entered into, it was in any event nullified by retrospective legislation. Mr Tooth had submitted his tax return claiming the loss (before the retrospective legislation was enacted) but as a partnership loss, rather than an employment loss (because he wanted to use the loss immediately against his tax liability for that year, and the software in the electronic tax returns would not permit the entry of the relevant figures into the box for employment losses). Mr Tooth had informed HMRC in the “white space” to the return that the loss he claimed was an ...
published: 14 May 2021 -
X Ltd & others –v- Her Majesty’s Revenue & Customs
Thursday 10th June 2021 Before Lord Justice Underhill, Lord Justice Singh Lady Justice Simler By Appellants Notice filed on 31 March 2020 the 3 Taxpayer companies and 17 others (the Individuals) appeal, with permission to appeal in part from the Upper Tribunal (Tax and Chancery Chamber) , UTJJ Jonathan Richards & Thomas Scott sitting, their decision dated 20 January 2020 in respect of the refusal of the “Adversarial Hearing application” made by the Appellants below. In 2014 HMRC opened enquiries into the Taxpayers corporation tax self assessment returns. The parties are in dispute over the reliability of the Taxpayers’ records. In 2017 the Taxpayers applied to the FTT under paragraph 33 of Schedule 18 of the Finance Act 2008 for a direction requiring HMRC to close those enquiries by i...
published: 10 Jun 2021 -
HM Revenue and Customs
Her Majesty's Revenue and Customs is a non-ministerial department of the UK Government responsible for the collection of taxes, the payment of some forms of state support, and the administration of other regulatory regimes including the national minimum wage. HMRC was formed by the merger of the Inland Revenue and Her Majesty's Customs and Excise which took effect on 18 April 2005. The department's logo is the St Edward's Crown enclosed within a circle. This video is targeted to blind users. Attribution: Article text available under CC-BY-SA Creative Commons image source in video
published: 25 Oct 2015 -
CABINET PRESS BRIEFING (Thursday July 18th 2024)
CABINET PRESS BRIEFING (Thursday July 18th 2024)
published: 19 Jul 2024 -
M Sport Ltd –v- Her Majesty’s Revenue & Customs
10th December 2020 Before Lord Justice David Richards Lady Justice Rose Lord Justice Popplewell Application for permission to appeal the decision of Upper Tribunal Judge Elizabeth Cooke, sitting as a judge of the High Court, dated 22 January 2020, in which she ordered that there be no order as to costs. The substantive dispute to which this Costs Order relates was an application for judicial review of the decision to issue a Follower Notice and Accelerated Payment Notice. This dispute was settled when HMRC withdrew those notices.
published: 10 Dec 2020
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7:00
The Commissioners for Her Majesty's Revenue and Customs v The Investment Trust Companies
- Order: Reorder
- Duration: 7:00
- Uploaded Date: 11 Apr 2017
- views: 1185
[2017] UKSC 29
UKSC 2015/0057
The Commissioners for Her Majesty's Revenue and Customs (Appellants) v The Investment Trust Companies (in liquidation) (Respond...
[2017] UKSC 29
UKSC 2015/0057
The Commissioners for Her Majesty's Revenue and Customs (Appellants) v The Investment Trust Companies (in liquidation) (Respondents)
UKSC 2015/0058
The Commissioners for Her Majesty's Revenue and Customs (Respondents) v The Investment Trust Companies (in liquidation) (Appellants)
On appeal from the Court of Appeal (Civil Division) (England and Wales)
This case concerns a claim in unjust enrichment following mistaken payment of VAT. The nine claimants in this case The Investment Trust Companies, ("the ITCS") are closed-ended investment funds constituted as limited companies. Between 1992 and 2002 they received supplies of investment management services from their investment managers ("the Managers"). It was generally understood that these services did not qualify for exemption from VAT. Therefore the Managers charged VAT on these services on the assumption that it was due and the ITCs paid the invoice together with VAT. The Managers made periodic VAT returns accounting for the VAT charges as output tax, reclaimed input tax and paid HMRC the net difference. Following the decision of the CJEU in Claverhouse, it transpired that these supplies should have been exempt from VAT. Accordingly, the Managers made claims to HMRC under s.80 VATA 1994 for repayment of sums accounted for and paid by them in error. HMRC met these claims but did not include any amounts relating to periods which were time-barred under the three-year period then provided by the statutory recovery scheme ("the Dead Periods"). The repayments were also limited to the net amounts the Managers had paid (e.g. the notional £75) rather than the full £100 paid by the ITCs. The Managers paid what they received in cash to the ITCs. The ITCs were therefore left out of pocket in respect of (1) the amounts paid during the Dead Periods and (2) in respect of the other periods, the difference between what they had paid (the notional £100) and the lesser net amounts that were repaid (the notional £75). The ITCs now claim directly from HMRC in unjust enrichment on the ground that HMRC has been enriched by payments made under a mistake of law.
The Supreme Court unanimously allows the Commissioners’ appeal and dismisses the ITCs’ cross-appeal.
https://wn.com/The_Commissioners_For_Her_Majesty's_Revenue_And_Customs_V_The_Investment_Trust_Companies
[2017] UKSC 29
UKSC 2015/0057
The Commissioners for Her Majesty's Revenue and Customs (Appellants) v The Investment Trust Companies (in liquidation) (Respondents)
UKSC 2015/0058
The Commissioners for Her Majesty's Revenue and Customs (Respondents) v The Investment Trust Companies (in liquidation) (Appellants)
On appeal from the Court of Appeal (Civil Division) (England and Wales)
This case concerns a claim in unjust enrichment following mistaken payment of VAT. The nine claimants in this case The Investment Trust Companies, ("the ITCS") are closed-ended investment funds constituted as limited companies. Between 1992 and 2002 they received supplies of investment management services from their investment managers ("the Managers"). It was generally understood that these services did not qualify for exemption from VAT. Therefore the Managers charged VAT on these services on the assumption that it was due and the ITCs paid the invoice together with VAT. The Managers made periodic VAT returns accounting for the VAT charges as output tax, reclaimed input tax and paid HMRC the net difference. Following the decision of the CJEU in Claverhouse, it transpired that these supplies should have been exempt from VAT. Accordingly, the Managers made claims to HMRC under s.80 VATA 1994 for repayment of sums accounted for and paid by them in error. HMRC met these claims but did not include any amounts relating to periods which were time-barred under the three-year period then provided by the statutory recovery scheme ("the Dead Periods"). The repayments were also limited to the net amounts the Managers had paid (e.g. the notional £75) rather than the full £100 paid by the ITCs. The Managers paid what they received in cash to the ITCs. The ITCs were therefore left out of pocket in respect of (1) the amounts paid during the Dead Periods and (2) in respect of the other periods, the difference between what they had paid (the notional £100) and the lesser net amounts that were repaid (the notional £75). The ITCs now claim directly from HMRC in unjust enrichment on the ground that HMRC has been enriched by payments made under a mistake of law.
The Supreme Court unanimously allows the Commissioners’ appeal and dismisses the ITCs’ cross-appeal.
5:06
Anson v Commissioners for Her Majesty's Revenue and Customs
- Order: Reorder
- Duration: 5:06
- Uploaded Date: 01 Jul 2015
- views: 456
[2015] UKSC 44
UKSC 2013/0068
Anson (Appellant) v Commissioners for Her Majesty's Revenue and Customs (Respondent)
On appeal from the Court of Appeal (Civil ...
[2015] UKSC 44
UKSC 2013/0068
Anson (Appellant) v Commissioners for Her Majesty's Revenue and Customs (Respondent)
On appeal from the Court of Appeal (Civil Division) (England and Wales)
The appellant is a member of a Delaware limited liability company, whose members pay tax in the United States on their share of the company's profits. The appellant remitted all of his share of the company's profits to the UK (net of US taxes). The appellant was liable to pay UK tax only on income remitted to the UK, but that included his shares of the profits of the company for the period 6 April 1997 to 5 April 2004 ("the relevant period"), unless any double tax relief or domestic unilateral relief was available. HMRC decided that the appellant was not entitled to double tax relief and sought to levy tax on the appellant's share of the company’s profits for the relevant period. This appeal considered whether the appellant's liability to UK income tax in relation to his membership of a Delaware limited liability company is to be computed by reference to the same profits or income by reference to which the appellant's US tax liability is computed.
The Supreme Court unanimously allows Mr Anson’s appeal.
https://wn.com/Anson_V_Commissioners_For_Her_Majesty's_Revenue_And_Customs
[2015] UKSC 44
UKSC 2013/0068
Anson (Appellant) v Commissioners for Her Majesty's Revenue and Customs (Respondent)
On appeal from the Court of Appeal (Civil Division) (England and Wales)
The appellant is a member of a Delaware limited liability company, whose members pay tax in the United States on their share of the company's profits. The appellant remitted all of his share of the company's profits to the UK (net of US taxes). The appellant was liable to pay UK tax only on income remitted to the UK, but that included his shares of the profits of the company for the period 6 April 1997 to 5 April 2004 ("the relevant period"), unless any double tax relief or domestic unilateral relief was available. HMRC decided that the appellant was not entitled to double tax relief and sought to levy tax on the appellant's share of the company’s profits for the relevant period. This appeal considered whether the appellant's liability to UK income tax in relation to his membership of a Delaware limited liability company is to be computed by reference to the same profits or income by reference to which the appellant's US tax liability is computed.
The Supreme Court unanimously allows Mr Anson’s appeal.
- published: 01 Jul 2015
- views: 456
7:05
Commissioners for Her Majesty's Revenue and Customs v Pendragon plc and other
- Order: Reorder
- Duration: 7:05
- Uploaded Date: 10 Jun 2015
- views: 1612
[2015] UKSC 37
UKSC 2013/0197
Commissioners for Her Majesty's Revenue and Customs (Appellant) v Pendragon plc and others (Respondents)
On appeal from the Cou...
[2015] UKSC 37
UKSC 2013/0197
Commissioners for Her Majesty's Revenue and Customs (Appellant) v Pendragon plc and others (Respondents)
On appeal from the Court of Appeal (Civil Division) (England and Wales)
This appeal concerned the application of the European law principle of abuse of rights in the context of VAT. The respondents are members of the Pendragon group, the largest car sales group in Europe. In 2000 and in 2001, Pendragon implemented arrangements which by reference to the strict application of the relevant legislation resulted in a substantial VAT advantage. The Commissioners challenged the scheme as being abusive on the basis that the arrangements resulted in a taxing outcome contrary to the purpose of the legislation in circumstances in which that outcome was the intention of Pendragon. The First Tier Tribunal found on the facts that Pendragon had a commercial motive for the transactions and that the arrangements were not therefore abusive. The Upper Tribunal allowed HMRC’s appeal but the Court of Appeal reversed this decision. The issue in this case is whether the scheme was abusive under the European law principle of abuse of rights.
The Supreme Court unanimously allows the appeal and holds that the scheme was abusive.
https://wn.com/Commissioners_For_Her_Majesty's_Revenue_And_Customs_V_Pendragon_Plc_And_Other
[2015] UKSC 37
UKSC 2013/0197
Commissioners for Her Majesty's Revenue and Customs (Appellant) v Pendragon plc and others (Respondents)
On appeal from the Court of Appeal (Civil Division) (England and Wales)
This appeal concerned the application of the European law principle of abuse of rights in the context of VAT. The respondents are members of the Pendragon group, the largest car sales group in Europe. In 2000 and in 2001, Pendragon implemented arrangements which by reference to the strict application of the relevant legislation resulted in a substantial VAT advantage. The Commissioners challenged the scheme as being abusive on the basis that the arrangements resulted in a taxing outcome contrary to the purpose of the legislation in circumstances in which that outcome was the intention of Pendragon. The First Tier Tribunal found on the facts that Pendragon had a commercial motive for the transactions and that the arrangements were not therefore abusive. The Upper Tribunal allowed HMRC’s appeal but the Court of Appeal reversed this decision. The issue in this case is whether the scheme was abusive under the European law principle of abuse of rights.
The Supreme Court unanimously allows the appeal and holds that the scheme was abusive.
- published: 10 Jun 2015
- views: 1612
3:56
Commissioners for Her Majesty's Revenue and Customs v The Rank Group PLC
- Order: Reorder
- Duration: 3:56
- Uploaded Date: 08 Jul 2015
- views: 555
[2015] UKSC 48
UKSC 2013/0257
Commissioners for Her Majesty's Revenue and Customs (Respondent) v The Rank Group PLC (Appellant)
On appeal from the Court of ...
[2015] UKSC 48
UKSC 2013/0257
Commissioners for Her Majesty's Revenue and Customs (Respondent) v The Rank Group PLC (Appellant)
On appeal from the Court of Appeal (Civil Division) (England and Wales)
This appeal considered whether the element of chance in a slot machine connected to a detached random number generator (RNG) which is used by several such machines is 'provided by means of the machine'. The appellant, Rank Group, is a gaming business. One type of slot machine they use is hooked up to a central RNG servicing several slot machines, instead of having an individual RNG inside each slot machine. If, notwithstanding this physical separation, the element of chance is provided 'by means of the machine', in the words of the relevant legislation, they will be liable to VAT on the takings from the machines. Rank contend that the element of chance is not so provided, and hence that they are entitled to a refund of VAT, while HMRC contend that it is. The Court of Appeal agreed with HMRC.
The Supreme Court unanimously dismisses the appeal.
https://wn.com/Commissioners_For_Her_Majesty's_Revenue_And_Customs_V_The_Rank_Group_Plc
[2015] UKSC 48
UKSC 2013/0257
Commissioners for Her Majesty's Revenue and Customs (Respondent) v The Rank Group PLC (Appellant)
On appeal from the Court of Appeal (Civil Division) (England and Wales)
This appeal considered whether the element of chance in a slot machine connected to a detached random number generator (RNG) which is used by several such machines is 'provided by means of the machine'. The appellant, Rank Group, is a gaming business. One type of slot machine they use is hooked up to a central RNG servicing several slot machines, instead of having an individual RNG inside each slot machine. If, notwithstanding this physical separation, the element of chance is provided 'by means of the machine', in the words of the relevant legislation, they will be liable to VAT on the takings from the machines. Rank contend that the element of chance is not so provided, and hence that they are entitled to a refund of VAT, while HMRC contend that it is. The Court of Appeal agreed with HMRC.
The Supreme Court unanimously dismisses the appeal.
- published: 08 Jul 2015
- views: 555
7:50
Routier and another (Appellants) v Commissioners for Her Majesty's Revenue and Customs (Respondent)
- Order: Reorder
- Duration: 7:50
- Uploaded Date: 16 Oct 2019
- views: 1041
[2019] UKSC 43
UKSC 2017/0190
Routier and another (Appellants) v Commissioners for Her Majesty's Revenue and Customs (Respondent)
On appeal from the Court...
[2019] UKSC 43
UKSC 2017/0190
Routier and another (Appellants) v Commissioners for Her Majesty's Revenue and Customs (Respondent)
On appeal from the Court of Appeal Civil Division (England and Wales)
On 9 October 2007 Mrs Beryl Coulter died in Jersey, and by her will she left her residuary estate on trust for either the building of homes for the elderly of the parish, or to an organisation called Jersey Hospice Care. Her will was drafted to be governed by the law of Jersey. Her executors (the Appellants) considered that the gift should be exempted from inheritance tax under s. 23 of the Inheritance Tax Act 1984 as it was for charitable purposes. HMRC however disagreed, and determined that the gift was liable to inheritance tax of approximately £600,000. The executors appealed this decision to the High Court, but the first-instance judge found for HMRC. It was held that for the exemption to apply required not only that the gift be for charitable purposes under UK law, but also that the relevant trust be subject to the jurisdiction of a UK court (which was not the case for Mrs Coulter’s trust). The appellants appealed again, and this time were given permission to argue, additionally, that such a construction of s.23 constituted an unlawful restriction on the free movement of capital between Member States and third countries within the meaning of Article 63 TFEU. Such arguments were, however, unsuccessful before the Court of Appeal, and the appellants now seek to appeal again to the Supreme Court.
The issue is:
Whether a disposition to a charitable trust in a will subject to the law of Jersey should be exempt from inheritance tax under s. 23 of the Inheritance Tax Act 1984 and whether, if the disposition is held not to be so exempt in domestic law, this constitutes an unlawful restriction on the movement of capital under Article 63 TFEU.
The Supreme Court unanimously allows the appeal.
https://wn.com/Routier_And_Another_(Appellants)_V_Commissioners_For_Her_Majesty's_Revenue_And_Customs_(Respondent)
[2019] UKSC 43
UKSC 2017/0190
Routier and another (Appellants) v Commissioners for Her Majesty's Revenue and Customs (Respondent)
On appeal from the Court of Appeal Civil Division (England and Wales)
On 9 October 2007 Mrs Beryl Coulter died in Jersey, and by her will she left her residuary estate on trust for either the building of homes for the elderly of the parish, or to an organisation called Jersey Hospice Care. Her will was drafted to be governed by the law of Jersey. Her executors (the Appellants) considered that the gift should be exempted from inheritance tax under s. 23 of the Inheritance Tax Act 1984 as it was for charitable purposes. HMRC however disagreed, and determined that the gift was liable to inheritance tax of approximately £600,000. The executors appealed this decision to the High Court, but the first-instance judge found for HMRC. It was held that for the exemption to apply required not only that the gift be for charitable purposes under UK law, but also that the relevant trust be subject to the jurisdiction of a UK court (which was not the case for Mrs Coulter’s trust). The appellants appealed again, and this time were given permission to argue, additionally, that such a construction of s.23 constituted an unlawful restriction on the free movement of capital between Member States and third countries within the meaning of Article 63 TFEU. Such arguments were, however, unsuccessful before the Court of Appeal, and the appellants now seek to appeal again to the Supreme Court.
The issue is:
Whether a disposition to a charitable trust in a will subject to the law of Jersey should be exempt from inheritance tax under s. 23 of the Inheritance Tax Act 1984 and whether, if the disposition is held not to be so exempt in domestic law, this constitutes an unlawful restriction on the movement of capital under Article 63 TFEU.
The Supreme Court unanimously allows the appeal.
- published: 16 Oct 2019
- views: 1041
7:38
Commissioners for Her Majesty’s Revenue and Customs (Appellant) v Tooth (Respondent)
- Order: Reorder
- Duration: 7:38
- Uploaded Date: 14 May 2021
- views: 1097
UKSC 2019/0136
On appeal from the Court of Appeal Civil Division (England and Wales)
Mr Tooth entered into an arrangement to obtain an employment loss (“Roman...
UKSC 2019/0136
On appeal from the Court of Appeal Civil Division (England and Wales)
Mr Tooth entered into an arrangement to obtain an employment loss (“Romangate”). Whether or not the arrangement achieved its objective at the time it was entered into, it was in any event nullified by retrospective legislation. Mr Tooth had submitted his tax return claiming the loss (before the retrospective legislation was enacted) but as a partnership loss, rather than an employment loss (because he wanted to use the loss immediately against his tax liability for that year, and the software in the electronic tax returns would not permit the entry of the relevant figures into the box for employment losses). Mr Tooth had informed HMRC in the “white space” to the return that the loss he claimed was an employment related loss. HMRC issued a discovery assessment on Mr Tooth (after the enactment of the legislation which nullified the arrangement) on the basis that: (1) HMRC had discovered an insufficiency in Mr Tooth’s return; (2) Mr Tooth’s return contained an inaccuracy (in that the loss was entered on the partnership pages of the return and Mr Tooth’s explanation as to why he had done this did not alter the nature of what HMRC consider to be an inaccuracy); and (3) this inaccuracy was deliberate.
The issues are:
The issues are, in the context of the Taxes Management Act 1970, section 29, in circumstances where Mr Tooth, in his self-assessment tax return for 2007-08, entered a loss he claimed was an employment loss as a partnership loss but informed HMRC that the loss was, in fact, an employment loss:
(1) whether (and if so, how and when), on the facts of the case, HMRC made a “discovery” of an insufficiency of tax in Mr Tooth’s income tax self-assessment return for 2007-08;
(2) whether a concept of “staleness” exists and, if so, how it applies in this case;
(3) whether Mr Tooth’s return contained an “inaccuracy” (in that the loss claimed was entered as a partnership loss, rather than an employment loss; HMRC say that Mr Tooth’s explanation in his return that the loss was, in fact, an employment loss does not prevent the entry of the loss in the partnership box from being an “inaccuracy”, whereas Mr Tooth says that his explanation that the loss claimed was an employment loss prevents there being an inaccuracy in his return at all) and
(4) if so, was that inaccuracy “deliberate”. It is common ground that the discovery assessment is valid if (and only if) the answer to each and every issue is determined in HMRC’s favour. Otherwise the discovery assessment is invalid.
The Supreme Court unanimously dismisses the Revenue’s appeal on the basis that there was no deliberate inaccuracy in Mr Tooth’s tax return.
More information is available on our website.
https://wn.com/Commissioners_For_Her_Majesty’S_Revenue_And_Customs_(Appellant)_V_Tooth_(Respondent)
UKSC 2019/0136
On appeal from the Court of Appeal Civil Division (England and Wales)
Mr Tooth entered into an arrangement to obtain an employment loss (“Romangate”). Whether or not the arrangement achieved its objective at the time it was entered into, it was in any event nullified by retrospective legislation. Mr Tooth had submitted his tax return claiming the loss (before the retrospective legislation was enacted) but as a partnership loss, rather than an employment loss (because he wanted to use the loss immediately against his tax liability for that year, and the software in the electronic tax returns would not permit the entry of the relevant figures into the box for employment losses). Mr Tooth had informed HMRC in the “white space” to the return that the loss he claimed was an employment related loss. HMRC issued a discovery assessment on Mr Tooth (after the enactment of the legislation which nullified the arrangement) on the basis that: (1) HMRC had discovered an insufficiency in Mr Tooth’s return; (2) Mr Tooth’s return contained an inaccuracy (in that the loss was entered on the partnership pages of the return and Mr Tooth’s explanation as to why he had done this did not alter the nature of what HMRC consider to be an inaccuracy); and (3) this inaccuracy was deliberate.
The issues are:
The issues are, in the context of the Taxes Management Act 1970, section 29, in circumstances where Mr Tooth, in his self-assessment tax return for 2007-08, entered a loss he claimed was an employment loss as a partnership loss but informed HMRC that the loss was, in fact, an employment loss:
(1) whether (and if so, how and when), on the facts of the case, HMRC made a “discovery” of an insufficiency of tax in Mr Tooth’s income tax self-assessment return for 2007-08;
(2) whether a concept of “staleness” exists and, if so, how it applies in this case;
(3) whether Mr Tooth’s return contained an “inaccuracy” (in that the loss claimed was entered as a partnership loss, rather than an employment loss; HMRC say that Mr Tooth’s explanation in his return that the loss was, in fact, an employment loss does not prevent the entry of the loss in the partnership box from being an “inaccuracy”, whereas Mr Tooth says that his explanation that the loss claimed was an employment loss prevents there being an inaccuracy in his return at all) and
(4) if so, was that inaccuracy “deliberate”. It is common ground that the discovery assessment is valid if (and only if) the answer to each and every issue is determined in HMRC’s favour. Otherwise the discovery assessment is invalid.
The Supreme Court unanimously dismisses the Revenue’s appeal on the basis that there was no deliberate inaccuracy in Mr Tooth’s tax return.
More information is available on our website.
- published: 14 May 2021
- views: 1097
2:11:26
X Ltd & others –v- Her Majesty’s Revenue & Customs
- Order: Reorder
- Duration: 2:11:26
- Uploaded Date: 10 Jun 2021
- views: 382
Thursday 10th June 2021
Before Lord Justice Underhill,
Lord Justice Singh
Lady Justice Simler
By Appellants Notice filed on 31 March 2020 the 3 Taxpayer compa...
Thursday 10th June 2021
Before Lord Justice Underhill,
Lord Justice Singh
Lady Justice Simler
By Appellants Notice filed on 31 March 2020 the 3 Taxpayer companies and 17 others (the Individuals) appeal, with permission to appeal in part from the Upper Tribunal (Tax and Chancery Chamber) , UTJJ Jonathan Richards & Thomas Scott sitting, their decision dated 20 January 2020 in respect of the refusal of the “Adversarial Hearing application” made by the Appellants below.
In 2014 HMRC opened enquiries into the Taxpayers corporation tax self assessment returns. The parties are in dispute over the reliability of the Taxpayers’ records. In 2017 the Taxpayers applied to the FTT under paragraph 33 of Schedule 18 of the Finance Act 2008 for a direction requiring HMRC to close those enquiries by issuing Closure Notices. In parallel HMRC applied to the FTT under Schedule 36 of the 2008 Act for approval of information notices requiring 17 Individuals (also Appellants below) to provide information considered by HMRC to be relevant to the Taxpayers’ tax position.
The FTT decided 1. to stay the Closure Notices application pending determination of the Schedule 36 application 2. it had no power to grant the Adversarial Hearing application (in which the Appellants below requested full rights to argue at an oral inter partes hearing , that the FTT should not approve the Schedule 36 application).
The UT dismissed the appeal in respect of the first decision. The UT concluded the FTT had no power to consider allowing or requiring participation by the Taxpayer or third party in the Schedule 36 application, but found the FTT’s decision it lacked jurisdiction to direct a hearing in public was wrong, although it will almost never do so. The UT remade the decision and came to the same conclusion that the Schedule 36 hearing should be heard in private.
https://wn.com/X_Ltd_Others_–V_Her_Majesty’S_Revenue_Customs
Thursday 10th June 2021
Before Lord Justice Underhill,
Lord Justice Singh
Lady Justice Simler
By Appellants Notice filed on 31 March 2020 the 3 Taxpayer companies and 17 others (the Individuals) appeal, with permission to appeal in part from the Upper Tribunal (Tax and Chancery Chamber) , UTJJ Jonathan Richards & Thomas Scott sitting, their decision dated 20 January 2020 in respect of the refusal of the “Adversarial Hearing application” made by the Appellants below.
In 2014 HMRC opened enquiries into the Taxpayers corporation tax self assessment returns. The parties are in dispute over the reliability of the Taxpayers’ records. In 2017 the Taxpayers applied to the FTT under paragraph 33 of Schedule 18 of the Finance Act 2008 for a direction requiring HMRC to close those enquiries by issuing Closure Notices. In parallel HMRC applied to the FTT under Schedule 36 of the 2008 Act for approval of information notices requiring 17 Individuals (also Appellants below) to provide information considered by HMRC to be relevant to the Taxpayers’ tax position.
The FTT decided 1. to stay the Closure Notices application pending determination of the Schedule 36 application 2. it had no power to grant the Adversarial Hearing application (in which the Appellants below requested full rights to argue at an oral inter partes hearing , that the FTT should not approve the Schedule 36 application).
The UT dismissed the appeal in respect of the first decision. The UT concluded the FTT had no power to consider allowing or requiring participation by the Taxpayer or third party in the Schedule 36 application, but found the FTT’s decision it lacked jurisdiction to direct a hearing in public was wrong, although it will almost never do so. The UT remade the decision and came to the same conclusion that the Schedule 36 hearing should be heard in private.
- published: 10 Jun 2021
- views: 382
14:38
HM Revenue and Customs
- Order: Reorder
- Duration: 14:38
- Uploaded Date: 25 Oct 2015
- views: 925
Her Majesty's Revenue and Customs is a non-ministerial department of the UK Government responsible for the collection of taxes, the payment of some forms of sta...
Her Majesty's Revenue and Customs is a non-ministerial department of the UK Government responsible for the collection of taxes, the payment of some forms of state support, and the administration of other regulatory regimes including the national minimum wage.
HMRC was formed by the merger of the Inland Revenue and Her Majesty's Customs and Excise which took effect on 18 April 2005. The department's logo is the St Edward's Crown enclosed within a circle.
This video is targeted to blind users.
Attribution:
Article text available under CC-BY-SA
Creative Commons image source in video
https://wn.com/Hm_Revenue_And_Customs
Her Majesty's Revenue and Customs is a non-ministerial department of the UK Government responsible for the collection of taxes, the payment of some forms of state support, and the administration of other regulatory regimes including the national minimum wage.
HMRC was formed by the merger of the Inland Revenue and Her Majesty's Customs and Excise which took effect on 18 April 2005. The department's logo is the St Edward's Crown enclosed within a circle.
This video is targeted to blind users.
Attribution:
Article text available under CC-BY-SA
Creative Commons image source in video
- published: 25 Oct 2015
- views: 925
34:01
CABINET PRESS BRIEFING (Thursday July 18th 2024)
- Order: Reorder
- Duration: 34:01
- Uploaded Date: 19 Jul 2024
- views: 319
CABINET PRESS BRIEFING (Thursday July 18th 2024)
CABINET PRESS BRIEFING (Thursday July 18th 2024)
https://wn.com/Cabinet_Press_Briefing_(Thursday_July_18Th_2024)
CABINET PRESS BRIEFING (Thursday July 18th 2024)
- published: 19 Jul 2024
- views: 319
2:30:10
M Sport Ltd –v- Her Majesty’s Revenue & Customs
- Order: Reorder
- Duration: 2:30:10
- Uploaded Date: 10 Dec 2020
- views: 503
10th December 2020
Before Lord Justice David Richards
Lady Justice Rose
Lord Justice Popplewell
Application for permission to appeal the decision of Upper Tri...
10th December 2020
Before Lord Justice David Richards
Lady Justice Rose
Lord Justice Popplewell
Application for permission to appeal the decision of Upper Tribunal Judge Elizabeth Cooke, sitting as a judge of the High Court, dated 22 January 2020, in which she ordered that there be no order as to costs.
The substantive dispute to which this Costs Order relates was an application for judicial review of the decision to issue a Follower Notice and Accelerated Payment Notice. This dispute was settled when HMRC withdrew those notices.
https://wn.com/M_Sport_Ltd_–V_Her_Majesty’S_Revenue_Customs
10th December 2020
Before Lord Justice David Richards
Lady Justice Rose
Lord Justice Popplewell
Application for permission to appeal the decision of Upper Tribunal Judge Elizabeth Cooke, sitting as a judge of the High Court, dated 22 January 2020, in which she ordered that there be no order as to costs.
The substantive dispute to which this Costs Order relates was an application for judicial review of the decision to issue a Follower Notice and Accelerated Payment Notice. This dispute was settled when HMRC withdrew those notices.
- published: 10 Dec 2020
- views: 503
7:00
The Commissioners for Her Majesty's Revenue and Customs v The Investment Trust Companies
[2017] UKSC 29
UKSC 2015/0057
The Commissioners for Her Majesty's Revenue and Customs (...
published: 11 Apr 2017
The Commissioners for Her Majesty's Revenue and Customs v The Investment Trust Companies
The Commissioners for Her Majesty's Revenue and Customs v The Investment Trust Companies
- Report rights infringement
- published: 11 Apr 2017
- views: 1185
[2017] UKSC 29
UKSC 2015/0057
The Commissioners for Her Majesty's Revenue and Customs (Appellants) v The Investment Trust Companies (in liquidation) (Respondents)
UKSC 2015/0058
The Commissioners for Her Majesty's Revenue and Customs (Respondents) v The Investment Trust Companies (in liquidation) (Appellants)
On appeal from the Court of Appeal (Civil Division) (England and Wales)
This case concerns a claim in unjust enrichment following mistaken payment of VAT. The nine claimants in this case The Investment Trust Companies, ("the ITCS") are closed-ended investment funds constituted as limited companies. Between 1992 and 2002 they received supplies of investment management services from their investment managers ("the Managers"). It was generally understood that these services did not qualify for exemption from VAT. Therefore the Managers charged VAT on these services on the assumption that it was due and the ITCs paid the invoice together with VAT. The Managers made periodic VAT returns accounting for the VAT charges as output tax, reclaimed input tax and paid HMRC the net difference. Following the decision of the CJEU in Claverhouse, it transpired that these supplies should have been exempt from VAT. Accordingly, the Managers made claims to HMRC under s.80 VATA 1994 for repayment of sums accounted for and paid by them in error. HMRC met these claims but did not include any amounts relating to periods which were time-barred under the three-year period then provided by the statutory recovery scheme ("the Dead Periods"). The repayments were also limited to the net amounts the Managers had paid (e.g. the notional £75) rather than the full £100 paid by the ITCs. The Managers paid what they received in cash to the ITCs. The ITCs were therefore left out of pocket in respect of (1) the amounts paid during the Dead Periods and (2) in respect of the other periods, the difference between what they had paid (the notional £100) and the lesser net amounts that were repaid (the notional £75). The ITCs now claim directly from HMRC in unjust enrichment on the ground that HMRC has been enriched by payments made under a mistake of law.
The Supreme Court unanimously allows the Commissioners’ appeal and dismisses the ITCs’ cross-appeal.
5:06
Anson v Commissioners for Her Majesty's Revenue and Customs
[2015] UKSC 44
UKSC 2013/0068
Anson (Appellant) v Commissioners for Her Majesty's Reven...
published: 01 Jul 2015
Anson v Commissioners for Her Majesty's Revenue and Customs
Anson v Commissioners for Her Majesty's Revenue and Customs
- Report rights infringement
- published: 01 Jul 2015
- views: 456
[2015] UKSC 44
UKSC 2013/0068
Anson (Appellant) v Commissioners for Her Majesty's Revenue and Customs (Respondent)
On appeal from the Court of Appeal (Civil Division) (England and Wales)
The appellant is a member of a Delaware limited liability company, whose members pay tax in the United States on their share of the company's profits. The appellant remitted all of his share of the company's profits to the UK (net of US taxes). The appellant was liable to pay UK tax only on income remitted to the UK, but that included his shares of the profits of the company for the period 6 April 1997 to 5 April 2004 ("the relevant period"), unless any double tax relief or domestic unilateral relief was available. HMRC decided that the appellant was not entitled to double tax relief and sought to levy tax on the appellant's share of the company’s profits for the relevant period. This appeal considered whether the appellant's liability to UK income tax in relation to his membership of a Delaware limited liability company is to be computed by reference to the same profits or income by reference to which the appellant's US tax liability is computed.
The Supreme Court unanimously allows Mr Anson’s appeal.
7:05
Commissioners for Her Majesty's Revenue and Customs v Pendragon plc and other
[2015] UKSC 37
UKSC 2013/0197
Commissioners for Her Majesty's Revenue and Customs (Appe...
published: 10 Jun 2015
Commissioners for Her Majesty's Revenue and Customs v Pendragon plc and other
Commissioners for Her Majesty's Revenue and Customs v Pendragon plc and other
- Report rights infringement
- published: 10 Jun 2015
- views: 1612
[2015] UKSC 37
UKSC 2013/0197
Commissioners for Her Majesty's Revenue and Customs (Appellant) v Pendragon plc and others (Respondents)
On appeal from the Court of Appeal (Civil Division) (England and Wales)
This appeal concerned the application of the European law principle of abuse of rights in the context of VAT. The respondents are members of the Pendragon group, the largest car sales group in Europe. In 2000 and in 2001, Pendragon implemented arrangements which by reference to the strict application of the relevant legislation resulted in a substantial VAT advantage. The Commissioners challenged the scheme as being abusive on the basis that the arrangements resulted in a taxing outcome contrary to the purpose of the legislation in circumstances in which that outcome was the intention of Pendragon. The First Tier Tribunal found on the facts that Pendragon had a commercial motive for the transactions and that the arrangements were not therefore abusive. The Upper Tribunal allowed HMRC’s appeal but the Court of Appeal reversed this decision. The issue in this case is whether the scheme was abusive under the European law principle of abuse of rights.
The Supreme Court unanimously allows the appeal and holds that the scheme was abusive.
3:56
Commissioners for Her Majesty's Revenue and Customs v The Rank Group PLC
[2015] UKSC 48
UKSC 2013/0257
Commissioners for Her Majesty's Revenue and Customs (Resp...
published: 08 Jul 2015
Commissioners for Her Majesty's Revenue and Customs v The Rank Group PLC
Commissioners for Her Majesty's Revenue and Customs v The Rank Group PLC
- Report rights infringement
- published: 08 Jul 2015
- views: 555
[2015] UKSC 48
UKSC 2013/0257
Commissioners for Her Majesty's Revenue and Customs (Respondent) v The Rank Group PLC (Appellant)
On appeal from the Court of Appeal (Civil Division) (England and Wales)
This appeal considered whether the element of chance in a slot machine connected to a detached random number generator (RNG) which is used by several such machines is 'provided by means of the machine'. The appellant, Rank Group, is a gaming business. One type of slot machine they use is hooked up to a central RNG servicing several slot machines, instead of having an individual RNG inside each slot machine. If, notwithstanding this physical separation, the element of chance is provided 'by means of the machine', in the words of the relevant legislation, they will be liable to VAT on the takings from the machines. Rank contend that the element of chance is not so provided, and hence that they are entitled to a refund of VAT, while HMRC contend that it is. The Court of Appeal agreed with HMRC.
The Supreme Court unanimously dismisses the appeal.
7:50
Routier and another (Appellants) v Commissioners for Her Majesty's Revenue and Customs (Respondent)
[2019] UKSC 43
UKSC 2017/0190
Routier and another (Appellants) v Commissioners for He...
published: 16 Oct 2019
Routier and another (Appellants) v Commissioners for Her Majesty's Revenue and Customs (Respondent)
Routier and another (Appellants) v Commissioners for Her Majesty's Revenue and Customs (Respondent)
- Report rights infringement
- published: 16 Oct 2019
- views: 1041
[2019] UKSC 43
UKSC 2017/0190
Routier and another (Appellants) v Commissioners for Her Majesty's Revenue and Customs (Respondent)
On appeal from the Court of Appeal Civil Division (England and Wales)
On 9 October 2007 Mrs Beryl Coulter died in Jersey, and by her will she left her residuary estate on trust for either the building of homes for the elderly of the parish, or to an organisation called Jersey Hospice Care. Her will was drafted to be governed by the law of Jersey. Her executors (the Appellants) considered that the gift should be exempted from inheritance tax under s. 23 of the Inheritance Tax Act 1984 as it was for charitable purposes. HMRC however disagreed, and determined that the gift was liable to inheritance tax of approximately £600,000. The executors appealed this decision to the High Court, but the first-instance judge found for HMRC. It was held that for the exemption to apply required not only that the gift be for charitable purposes under UK law, but also that the relevant trust be subject to the jurisdiction of a UK court (which was not the case for Mrs Coulter’s trust). The appellants appealed again, and this time were given permission to argue, additionally, that such a construction of s.23 constituted an unlawful restriction on the free movement of capital between Member States and third countries within the meaning of Article 63 TFEU. Such arguments were, however, unsuccessful before the Court of Appeal, and the appellants now seek to appeal again to the Supreme Court.
The issue is:
Whether a disposition to a charitable trust in a will subject to the law of Jersey should be exempt from inheritance tax under s. 23 of the Inheritance Tax Act 1984 and whether, if the disposition is held not to be so exempt in domestic law, this constitutes an unlawful restriction on the movement of capital under Article 63 TFEU.
The Supreme Court unanimously allows the appeal.
7:38
Commissioners for Her Majesty’s Revenue and Customs (Appellant) v Tooth (Respondent)
UKSC 2019/0136
On appeal from the Court of Appeal Civil Division (England and Wales)
Mr ...
published: 14 May 2021
Commissioners for Her Majesty’s Revenue and Customs (Appellant) v Tooth (Respondent)
Commissioners for Her Majesty’s Revenue and Customs (Appellant) v Tooth (Respondent)
- Report rights infringement
- published: 14 May 2021
- views: 1097
UKSC 2019/0136
On appeal from the Court of Appeal Civil Division (England and Wales)
Mr Tooth entered into an arrangement to obtain an employment loss (“Romangate”). Whether or not the arrangement achieved its objective at the time it was entered into, it was in any event nullified by retrospective legislation. Mr Tooth had submitted his tax return claiming the loss (before the retrospective legislation was enacted) but as a partnership loss, rather than an employment loss (because he wanted to use the loss immediately against his tax liability for that year, and the software in the electronic tax returns would not permit the entry of the relevant figures into the box for employment losses). Mr Tooth had informed HMRC in the “white space” to the return that the loss he claimed was an employment related loss. HMRC issued a discovery assessment on Mr Tooth (after the enactment of the legislation which nullified the arrangement) on the basis that: (1) HMRC had discovered an insufficiency in Mr Tooth’s return; (2) Mr Tooth’s return contained an inaccuracy (in that the loss was entered on the partnership pages of the return and Mr Tooth’s explanation as to why he had done this did not alter the nature of what HMRC consider to be an inaccuracy); and (3) this inaccuracy was deliberate.
The issues are:
The issues are, in the context of the Taxes Management Act 1970, section 29, in circumstances where Mr Tooth, in his self-assessment tax return for 2007-08, entered a loss he claimed was an employment loss as a partnership loss but informed HMRC that the loss was, in fact, an employment loss:
(1) whether (and if so, how and when), on the facts of the case, HMRC made a “discovery” of an insufficiency of tax in Mr Tooth’s income tax self-assessment return for 2007-08;
(2) whether a concept of “staleness” exists and, if so, how it applies in this case;
(3) whether Mr Tooth’s return contained an “inaccuracy” (in that the loss claimed was entered as a partnership loss, rather than an employment loss; HMRC say that Mr Tooth’s explanation in his return that the loss was, in fact, an employment loss does not prevent the entry of the loss in the partnership box from being an “inaccuracy”, whereas Mr Tooth says that his explanation that the loss claimed was an employment loss prevents there being an inaccuracy in his return at all) and
(4) if so, was that inaccuracy “deliberate”. It is common ground that the discovery assessment is valid if (and only if) the answer to each and every issue is determined in HMRC’s favour. Otherwise the discovery assessment is invalid.
The Supreme Court unanimously dismisses the Revenue’s appeal on the basis that there was no deliberate inaccuracy in Mr Tooth’s tax return.
More information is available on our website.
2:11:26
X Ltd & others –v- Her Majesty’s Revenue & Customs
Thursday 10th June 2021
Before Lord Justice Underhill,
Lord Justice Singh
Lady Justice Si...
published: 10 Jun 2021
X Ltd & others –v- Her Majesty’s Revenue & Customs
X Ltd & others –v- Her Majesty’s Revenue & Customs
- Report rights infringement
- published: 10 Jun 2021
- views: 382
Thursday 10th June 2021
Before Lord Justice Underhill,
Lord Justice Singh
Lady Justice Simler
By Appellants Notice filed on 31 March 2020 the 3 Taxpayer companies and 17 others (the Individuals) appeal, with permission to appeal in part from the Upper Tribunal (Tax and Chancery Chamber) , UTJJ Jonathan Richards & Thomas Scott sitting, their decision dated 20 January 2020 in respect of the refusal of the “Adversarial Hearing application” made by the Appellants below.
In 2014 HMRC opened enquiries into the Taxpayers corporation tax self assessment returns. The parties are in dispute over the reliability of the Taxpayers’ records. In 2017 the Taxpayers applied to the FTT under paragraph 33 of Schedule 18 of the Finance Act 2008 for a direction requiring HMRC to close those enquiries by issuing Closure Notices. In parallel HMRC applied to the FTT under Schedule 36 of the 2008 Act for approval of information notices requiring 17 Individuals (also Appellants below) to provide information considered by HMRC to be relevant to the Taxpayers’ tax position.
The FTT decided 1. to stay the Closure Notices application pending determination of the Schedule 36 application 2. it had no power to grant the Adversarial Hearing application (in which the Appellants below requested full rights to argue at an oral inter partes hearing , that the FTT should not approve the Schedule 36 application).
The UT dismissed the appeal in respect of the first decision. The UT concluded the FTT had no power to consider allowing or requiring participation by the Taxpayer or third party in the Schedule 36 application, but found the FTT’s decision it lacked jurisdiction to direct a hearing in public was wrong, although it will almost never do so. The UT remade the decision and came to the same conclusion that the Schedule 36 hearing should be heard in private.
14:38
HM Revenue and Customs
Her Majesty's Revenue and Customs is a non-ministerial department of the UK Government res...
published: 25 Oct 2015
HM Revenue and Customs
HM Revenue and Customs
- Report rights infringement
- published: 25 Oct 2015
- views: 925
Her Majesty's Revenue and Customs is a non-ministerial department of the UK Government responsible for the collection of taxes, the payment of some forms of state support, and the administration of other regulatory regimes including the national minimum wage.
HMRC was formed by the merger of the Inland Revenue and Her Majesty's Customs and Excise which took effect on 18 April 2005. The department's logo is the St Edward's Crown enclosed within a circle.
This video is targeted to blind users.
Attribution:
Article text available under CC-BY-SA
Creative Commons image source in video
34:01
CABINET PRESS BRIEFING (Thursday July 18th 2024)
CABINET PRESS BRIEFING (Thursday July 18th 2024)
published: 19 Jul 2024
CABINET PRESS BRIEFING (Thursday July 18th 2024)
CABINET PRESS BRIEFING (Thursday July 18th 2024)
- Report rights infringement
- published: 19 Jul 2024
- views: 319
CABINET PRESS BRIEFING (Thursday July 18th 2024)
2:30:10
M Sport Ltd –v- Her Majesty’s Revenue & Customs
10th December 2020
Before Lord Justice David Richards
Lady Justice Rose
Lord Justice Popp...
published: 10 Dec 2020
M Sport Ltd –v- Her Majesty’s Revenue & Customs
M Sport Ltd –v- Her Majesty’s Revenue & Customs
- Report rights infringement
- published: 10 Dec 2020
- views: 503
10th December 2020
Before Lord Justice David Richards
Lady Justice Rose
Lord Justice Popplewell
Application for permission to appeal the decision of Upper Tribunal Judge Elizabeth Cooke, sitting as a judge of the High Court, dated 22 January 2020, in which she ordered that there be no order as to costs.
The substantive dispute to which this Costs Order relates was an application for judicial review of the decision to issue a Follower Notice and Accelerated Payment Notice. This dispute was settled when HMRC withdrew those notices.
HM Revenue and Customs
Her Majesty's Revenue and Customs (HM Revenue and Customs or HMRC) is a non-ministerial department of the UK Government responsible for the collection of taxes, the payment of some forms of state support, and the administration of other regulatory regimes including the national minimum wage.
HMRC was formed by the merger of the Inland Revenue and Her Majesty's Customs and Excise which took effect on 18 April 2005. The department's logo is the St Edward's Crown enclosed within a circle.
Departmental responsibilities
The department is responsible for the administration and collection of direct taxes including income tax and corporation tax, capital taxes such as capital gains tax and inheritance tax, indirect taxes (including value added tax), excise duties and stamp duty land tax, and environmental taxes such as Air Passenger Duty and the climate change levy. Other aspects of the department's responsibilities include National Insurance contributions, the distribution of child benefit and some other forms of state support including the Child Trust Fund, payments of Tax Credits, enforcement of the national minimum wage, administering anti-money laundering registrations for Money Service Businesses and collection and publication of the trade-in-goods statistics. Responsibility for the protection of the UK's borders passed to UK Visas and Immigration the of UK Border Agency within the Home Office on 1 April 2008 and then to UK Visas and Immigration in 2013.
This page contains text from Wikipedia, the Free Encyclopedia - https://wn.com/HM_Revenue_and_Customs
The Commissioners for Her Majesty's Revenue and Cu...
Anson v Commissioners for Her Majesty's Revenue a...
Commissioners for Her Majesty's Revenue and Custom...
Commissioners for Her Majesty's Revenue and Custom...
Routier and another (Appellants) v Commissioners f...
Commissioners for Her Majesty’s Revenue and Custom...
X Ltd & others –v- Her Majesty’s Revenue & Customs...
HM Revenue and Customs...
CABINET PRESS BRIEFING (Thursday July 18th 2024)...
M Sport Ltd –v- Her Majesty’s Revenue & Customs...
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by The Beatles
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by Her Majesty
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by Her Majesty
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by Her Majesty
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by Her Majesty
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by Yellow Matter Custard
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by Her Majesty
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by Her Majesty
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by Her Majesty
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by Her Majesty
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by Her Majesty
Her Majesty
by: The BeatlesHer Majesty's a pretty nice girl
But she doesn't have a lot to say
Her Majesty's a pretty nice girl
But she changes from day to day
I want to tell her that I love her a lot
But I gotta get a bellyful of wine
Her Majesty's a pretty nice girl
Someday I'm going to make her mine, oh yeah
Someday I'm going to make her mine