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K Percival v HMRC

In K Percival v HMRC [2016] UKFTT 308 (5 May 2016) the FTT found that it did not have jurisdiction to hear an appeal against a decision made by a complaints department of HMRC.

Mr Percival a resident in the Republic of Ireland had exchanged correspondence with HMRC relating to the taxation of his pension in the UK. At the conclusion of the correspondence HMRC had decided that his pension was fully taxable in the UK under the UK/Ireland double tax treaty and indicated steps Mr Percival could take if he felt that his complaint had not been dealt with properly. Instead of following these steps the taxpayer had lodged an appeal with HM Courts & Tribunals Service which had informed him that HMRC’s decision was not appealable. However following further correspondence the appeal had been allocated to proceed under the standard...

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