06 March 2017
UT Decision: The Commissioners for Her Majesty’s Revenue and Customs v Sippchoice Limited
INCOME TAX – scheme sanction charges – FA 2009 s 269 – whether scheme administrator reasonably believed that no unauthorised payment was being made – s 268(7)(a) – whether FTT erred in its interpretation and application of the test of reasonableness – Mobilx considered – whether FTT made an error of law in its findings of fact – Edwards v Bairstow.
Laura Poots, instructed by the General Counsel and Solicitor to HM Revenue and Customs, for the Appellants.
To see the approved Decision, click here.
This content is provided free of charge for information purposes only. It does not constitute legal advice and should not be relied on as such. No responsibility for the accuracy and/or correctness of the information and commentary set out in the article, or for any consequences of relying on it, is assumed or accepted by any member of PCTC or by PCTC as a whole.