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.