The Queen on the Application of Telefonica Europe Plc and Telefonica UK Limited v The Commissioners for HM Revenue and Customs: [2016] UKUT 0173 (TCC)

Upper Tribunal Tax and Chancery decision of Mrs Justice Rose DBE and Judge Sinfield on 15 April 2016.

Read the full decision in The Queen on the Application of Telefonica Europe Plc and Telefonica UK Limited v The Commissioners for HM Revenue and Customs: [2016] UKUT 0173 (TCC).

JUDICIAL REVIEW – determining place of effective use and enjoyment of telecommunications services - whether methodology for apportioning charge between EU and non-EU services based on usage is unlawful – whether claimants had legitimate expectation derived from correspondence with HMRC that claimants could continue to use methodology based on revenues until change in law or claimant’s business – whether HMRC had duty to consult claimants before requiring them to apply a new methodology – whether HMRC consulted claimants adequately.

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