Mark Whitehouse Tax Litigation Reynolds Porter Chamberlain LLP looks at the implications of the Condé Nast decision for EU direct tax claims against HMRC
The House of Lords dealt a serious blow to HMRC in respect of potential reclaims of VAT in its decision in the joined cases Fleming (t/a Bodycraft) and Condé Nast v HMRC.1 This article does not deal with the VAT consequence of the decision.2 The decision has however impact in relation to direct tax claims that have been made against HMRC: claims involving the application of EU fundamental freedoms (the tax Group Litigation Orders or GLOs). There is perhaps one last important opportunity to make claims: a significant chink in HMRC's armour. In this article I will seek to outline that opportunity.
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Mark Whitehouse Tax Litigation Reynolds Porter Chamberlain LLP looks at the implications of the Condé Nast decision for EU direct tax claims against HMRC
The House of Lords dealt a serious blow to HMRC in respect of potential reclaims of VAT in its decision in the joined cases Fleming (t/a Bodycraft) and Condé Nast v HMRC.1 This article does not deal with the VAT consequence of the decision.2 The decision has however impact in relation to direct tax claims that have been made against HMRC: claims involving the application of EU fundamental freedoms (the tax Group Litigation Orders or GLOs). There is perhaps one last important opportunity to make claims: a significant chink in HMRC's armour. In this article I will seek to outline that opportunity.
...
If you are not a subscriber, subscribe now to read this content.
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