The Commissioners for HM Revenue and Customs v Volkerrail Plant Limited, Volkerrail Power Limited, VolkerFitxPatrick Limited, Volkerrail Limited [2022] UKUT 00078 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Roth and Judge Jonathan Richards on 07 March 2022

Read full decision in HMRC v VolkerRail UT-2021-000014 CORPORATION TAX – Whether s403D(1)(c) of ICTA constitutes unlawful restriction on freedom of establishment – yes because, while justified, it operates disproportionately – conforming interpretation adopted – appeal allowed

Published 14 March 2022