MWL International Limited & Maywal Limited v HMRC [2026] UKUT 00062 (TCC)
Upper Tribunal Tax and Chancery Decision of Mr Justice Adam Johnson and Judge Thomas Scott on 6 February 2026.
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NATIONAL INSURANCE CONTRIBUTIONS – agreement with inspector of taxes that certain cars would be “pooled cars” for NICs purposes if various conditions satisfied – HMRC subsequently sought to collect NICs retrospectively – whether HMRC estopped from doing so – whether the FTT had jurisdiction to decide whether Appellants had legitimate expectation that decisions would not be retrospective – appeal dismissed