David Pickstone (Stewarts Law) reviews the recent Upper Tribunal decision in Ingenious, which considered whether HMRC could make allegations of dishonesty at a late stage in proceedings without having pleaded them in its statement of case.
The case of Ingenious Games v HMRC [2015] UKUT 0105 (reported in Tax Journal 13 March 2015) is the second time that the Upper Tribunal has been asked to determine case management issues arising from the joined appeals brought by three LLPs operated by Ingenious Media Holdings Plc (‘Ingenious Media’). This time the issues arise from an application brought by the Ingenious LLPs to adjourn the First-tier Tribunal proceedings following developments in HMRC’s arguments which were tantamount to allegations of dishonesty.
Before looking in detail at the Upper Tribunal’s decision it is worth taking a brief look at the context of the broader appeals.
Background
In 2012 HMRC...
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David Pickstone (Stewarts Law) reviews the recent Upper Tribunal decision in Ingenious, which considered whether HMRC could make allegations of dishonesty at a late stage in proceedings without having pleaded them in its statement of case.
The case of Ingenious Games v HMRC [2015] UKUT 0105 (reported in Tax Journal 13 March 2015) is the second time that the Upper Tribunal has been asked to determine case management issues arising from the joined appeals brought by three LLPs operated by Ingenious Media Holdings Plc (‘Ingenious Media’). This time the issues arise from an application brought by the Ingenious LLPs to adjourn the First-tier Tribunal proceedings following developments in HMRC’s arguments which were tantamount to allegations of dishonesty.
Before looking in detail at the Upper Tribunal’s decision it is worth taking a brief look at the context of the broader appeals.
Background
In 2012 HMRC...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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