Market leading insight for tax experts
View online issue

Sumitomo Mitsui Banking Corporation Europe Ltd v HMRC (No 2)

Administration and appeals: Appeal dismissed but costs awarded to appellant

The case of Sumitomo Mitsui Banking Corporation Europe Ltd v HMRC (No 2) (TC00505 – 18 May) follows on from Tribunal Decision TC00089 where the Tribunal upheld HMRC's contention that certain services had been supplied in the UK. Following this decision the company (E) applied for costs of more than £300 000 contending that HMRC had acted unreasonably in that the reasons given in their Skeleton Argument were significantly different from those given in their Statement of Case and that it had only received HMRC's Skeleton Argument three days before the hearing of the appeal. The Tribunal found that 'there was a material and substantive difference between HMRC's skeleton argument and its statement of case' but held that the amount which E had claimed was excessive. The Tribunal ordered that HMRC should pay E costs...

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.