THE KING (on the application of) RETTIG HEATING GROUP UK LIMITED (IN LIQUIDATION) v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2025] UKUT 00143 (TCC)

Upper Tribunal Tax and Chancery decision of MR JUSTICE EDWIN JOHNSON and UPPER TRIBUNAL JUDGE SWAMI RAGHAVAN on 06 May 2025

From:
HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
Published
6 May 2025
Category:
Tax
Release date:
6 May 2025

Read full decision THE KING (on the application of) RETTIG HEATING GROUP UK LIMITED (IN LIQUIDATION) v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

JUDICIAL REVIEW – HMRC’s refusal to exercise discretion to extend time, in relation to a claim to set off NTLRD against profits that arose from the Claimant’s dividend income from a foreign subsidiary received in accounting period ended 31 December 2002 – whether HMRC misinterpreted or misapplied Statement of Practice (05/01) and whether HMRC refusal irrational – no – claim dismissed

Updates to this page

Published 6 May 2025