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Charles Elphicke and Sandy Bhogal, Mayer Brown Rowe & Maw LLP, discuss a decision involving the interpretation of the Halifax principle to an application for disclosure under the VAT Tribunal Rules

 
Charles Elphicke and Sandy Bhogal Mayer Brown Rowe & Maw LLP discuss a decision involving the interpretation of the Halifax principle to an application for disclosure under the VAT Tribunal Rules
 
In the case of MMO2 v HMRC 1 the VAT & Duties Tribunal allowed an application by HMRC for disclosure under Rule 20(3) of the VAT Tribunal Rules 1986 (SI 1986 No 590). This application was made on the basis that HMRC had formed the opinion that the taxpayer had engaged in a tax avoidance scheme and that this constituted an 'abusive practice' within the scope of the...

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