Market leading insight for tax experts
View online issue

K McCabe v HMRC

HMRC was not required to disclose documents relating to MAP 

In K McCabe v HMRC [2020] UKUT 266 (TCC) (21 September 2020) the Upper Tribunal (UT) upheld a decision of the First-tier Tribunal (FTT) not to require HMRC to disclose documents relating to the application in the taxpayer’s case of the mutual agreement procedure (MAP) under the UK/Belgium double tax treaty.

Mr McCabe had appealed to the FTT against various closure notices contending that he was not resident in the UK or alternatively that he was resident in Belgium under the UK-Belgium double tax treaty. He instigated the MAP under the treaty. This resulted in an agreement between the UK and Belgian tax authorities that Mr McCabe was UK-resident for tax purposes. Mr McCabe did not accept that agreement and applied to HMRC to disclose documents relating to the application of the MAP. When HMRC refused ...

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:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top