In R (oao Haworth) v HMRC [2021] UKSC 25 (reported in Tax Journal 9 July 2021) the Supreme Court dismissed HMRC’s appeal and upheld the Court of Appeal decision to quash the follower notice (FN) and the accelerated payment notice (APN) based on the FN. This was because HMRC had not formed the requisite opinion that the final judicial ruling underpinning the FN was ‘relevant’ to the taxpayer’s arrangements.
The decision essentially hinged on the interpretation of the word ‘would’ in FA 2014 s 205(3)(b) which is one of the conditions required for a judicial ruling to be ‘relevant’ to another taxpayer’s tax arrangements for the purpose of issuing an FN to that taxpayer.
According to the Supreme...
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In R (oao Haworth) v HMRC [2021] UKSC 25 (reported in Tax Journal 9 July 2021) the Supreme Court dismissed HMRC’s appeal and upheld the Court of Appeal decision to quash the follower notice (FN) and the accelerated payment notice (APN) based on the FN. This was because HMRC had not formed the requisite opinion that the final judicial ruling underpinning the FN was ‘relevant’ to the taxpayer’s arrangements.
The decision essentially hinged on the interpretation of the word ‘would’ in FA 2014 s 205(3)(b) which is one of the conditions required for a judicial ruling to be ‘relevant’ to another taxpayer’s tax arrangements for the purpose of issuing an FN to that taxpayer.
According to the Supreme...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
