THE KING (ON THE APPLICATION OF) (1) FLUID SYSTEM TECHNOLOGIES (SCOTLAND) LIMITED (2) LONDON FLUID SYSTEM TECHNOLOGIES LIMITED v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2025] UKUT 00278 (TCC)
Upper Tribunal Tax and Chancery decision of MRS JUSTICE BACON and JUDGE SWAMI RAGHAVAN on 15 August 2025
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JUDICIAL REVIEW – challenge to HMRC decisions made under the Disguised Remuneration Repayment Scheme – whether repayment eligibility conditions that HMRC had “no power to recover” or that the claimant had made “reasonable disclosure” of relevant loans met –quashing and mandatory orders refused
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Published 19 August 2025