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Halifax — the European Impact

Michael Ridsdale of Wedlake Bell considers what impact Halifax has had in Europe with contributions from other member firms of the TELFA (Trans European Law Firms Alliance) network
A little over five months have elapsed since the European Court of Justice delivered its judgment in Halifax and others v Commissioners of Customs & Excise which marked the end of around five years of litigation.
Looking at the picture from a UK perspective we know and HMRC has publicly stated that HMRC is going to adopt an aggressive stance when asserting that an abusive practice exists (see The Tax Journal Issue 833 17 April 2006). This is notwithstanding that HMRC appears to be construing Halifax in a manner that is likely to be inconsistent...

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