E Buyer UK Limited v The Commissioners for HM Revenue and Customs and The Commissioners for HM Revenue and Customs v Citibank NA: [2016] UKUT 0123 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Nugee and Judge Herrington on 10 March 2016.

Read the full decision in E Buyer UK Limited v The Commissioners for HM Revenue and Customs and The Commissioners for HM Revenue and Customs v Citibank NA: [2016] UKUT 0123 (TCC).

PROCEDURE – MTIC appeals - allegations of knowledge that appellant’s transactions orchestrated and contrived and formed part of an overall scheme to defraud the Revenue - whether HMRC’s statement of case alleged dishonesty and therefore whether sufficiently particularised - whether standard disclosure of relevant documents appropriate.

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