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 .
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
Published 2 March 2017