Disclosure of documents in loan charge case: K (oao Airedale Chemical Company Ltd) v HMRC [2025] UKUT 65 (TCC) (20 February 2025) is another case arising from the controversy about the loan charge. Following the Morse review HMRC established a scheme under which certain sums which had been paid to HMRC in disguised remuneration cases could be repaid. In this particular case HMRC had refused to make repayment on the basis that the requirements of the scheme were not met.
The taxpayers involved are taking judicial review proceedings against HMRC arguing about the lawfulness of HMRC’s decision makers’ action. In this preliminary hearing they sought disclosure of two groups of documents. The first was the background documents etc. which led to the drafting of HMRC’s operational guidance on how the scheme was to be administered. The Upper Tribunal (UT) accepted that the guidance itself was relevant (it...
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Disclosure of documents in loan charge case: K (oao Airedale Chemical Company Ltd) v HMRC [2025] UKUT 65 (TCC) (20 February 2025) is another case arising from the controversy about the loan charge. Following the Morse review HMRC established a scheme under which certain sums which had been paid to HMRC in disguised remuneration cases could be repaid. In this particular case HMRC had refused to make repayment on the basis that the requirements of the scheme were not met.
The taxpayers involved are taking judicial review proceedings against HMRC arguing about the lawfulness of HMRC’s decision makers’ action. In this preliminary hearing they sought disclosure of two groups of documents. The first was the background documents etc. which led to the drafting of HMRC’s operational guidance on how the scheme was to be administered. The Upper Tribunal (UT) accepted that the guidance itself was relevant (it...
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