HMRC permission to appeal against case management decisions refused
In BGC Services Holdings LLP v HMRC[2025] UKFTT 700 (TC) (9 June) the FTT refused HMRC permission to appeal to the UT against two case management decisions (i) refusing HMRC’s request for further and better particulars from the taxpayer and (ii) requiring HMRC to particularise in its statement of case how salaried members conditions were met for which partners how the determinations of over £96m was calculated and the basis for alleging deliberate or careless behaviour on the part of the taxpayer.
HMRC now have the right to appeal directly to the UT for permission to appeal the decisions.
In March 2024 HMRC made PAYE determinations of over £96m under PAYE regulations (SI 2003/2682 reg 80) in relation to the salaried members rules for 2017/18 to 2019/20 stating that ‘the...
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HMRC permission to appeal against case management decisions refused
In BGC Services Holdings LLP v HMRC[2025] UKFTT 700 (TC) (9 June) the FTT refused HMRC permission to appeal to the UT against two case management decisions (i) refusing HMRC’s request for further and better particulars from the taxpayer and (ii) requiring HMRC to particularise in its statement of case how salaried members conditions were met for which partners how the determinations of over £96m was calculated and the basis for alleging deliberate or careless behaviour on the part of the taxpayer.
HMRC now have the right to appeal directly to the UT for permission to appeal the decisions.
In March 2024 HMRC made PAYE determinations of over £96m under PAYE regulations (SI 2003/2682 reg 80) in relation to the salaried members rules for 2017/18 to 2019/20 stating that ‘the...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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