PHILLIP BRIAN HIGGS & OTHERS and THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2023] UKUT 00296 (TCC)
Upper Tribunal Tax and Chancery decision of JUDGE VINESH MANDALIA and JUDGE KEVIN POOLE on 13 December 2023
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Procedure – preliminary issue – marketed tax avoidance scheme – doctrine of precedent – the FtT does not have jurisdiction to consider whether a taxpayer was entitled to PAYE credits under Regulations 185 and 188 of the Income Tax (PAYE) Regulations 2003 for sums that end users were liable to deduct under PAYE.
Published 14 December 2023