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Great expectations? VAT and legitimate expectation

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Recent cases have clarified the circumstances in which the taxpayer has a legitimate expectation in the context of VAT. Such circumstances are now more readily identifiable and, where they arise, taxpayers should be encouraged to bring a claim for judicial review. However, the correct forum in which to bring such a claim is not always clear and care is therefore required in order to avoid either losing the right to bring a claim or incurring unnecessary costs.

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