The Commissioners for HM Revenue and Customs v Sippchoice Limited: [2017] UKUT 0087 (TCC)

Upper Tribunal Tax and Chancery decision of Judge Berner and Judge Cannan on 01 March 2017.

Read the full decision in The Commissioners for HM Revenue and Customs v Sippchoice Limited: [2017] UKUT 0087 (TCC).

INCOME TAX – scheme sanction charges – FA 2009 s 269 – whether scheme administrator reasonably believed that no unauthorised payment was being made – s 268(7)(a) – whether FTT erred in its interpretation and application of the test of reasonableness – Mobilx considered – whether FTT made an error of law in its findings of fact – Edwards v Bairstow

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