Charles Elphicke and Sandy Bhogal Mayer Brown Rowe & Maw LLP discuss a decision involving the interpretation of the Halifax principle to an application for disclosure under the VAT Tribunal Rules
In the case of MMO2 v HMRC1 the VAT & Duties Tribunal allowed an application by HMRC for disclosure under Rule 20(3) of the VAT Tribunal Rules 1986 (SI 1986 No 590). This application was made on the basis that HMRC had formed the opinion that the taxpayer had engaged in a tax avoidance scheme and that this constituted an 'abusive practice' within the scope of the CJEC decision in Halifax.2
Background
Under Rule 20(3) before ordering disclosure...
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Charles Elphicke and Sandy Bhogal Mayer Brown Rowe & Maw LLP discuss a decision involving the interpretation of the Halifax principle to an application for disclosure under the VAT Tribunal Rules
In the case of MMO2 v HMRC1 the VAT & Duties Tribunal allowed an application by HMRC for disclosure under Rule 20(3) of the VAT Tribunal Rules 1986 (SI 1986 No 590). This application was made on the basis that HMRC had formed the opinion that the taxpayer had engaged in a tax avoidance scheme and that this constituted an 'abusive practice' within the scope of the CJEC decision in Halifax.2
Background
Under Rule 20(3) before ordering disclosure...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
