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HMRC and Halifax
HMRC say that there are about 175 cases currently stood over pending the European Court of Justice's decisions in University of Huddersfield (Case C-223/03), BUPA Hospitals Ltd (Case C-419/02) and Halifax plc (Case C-255/02); see 'Whose victory?', Update, Taxation, 2 March 2006, page 553. Most of these cases have been stood over for 60 days after the date of the decision, i.e. until 22 April 2006. HMRC will use this period to review the disputed decisions in individual appeals in the light of the court's judgments but given the terms of those judgments they anticipate that most of disputed decisions will be maintained.
Since all of these cases are within the judicial appeal system, HMRC will correspond with appellants via their solicitor/representative of record. Any taxpayer who does not have an appeal but nevertheless thinks that they may be affected by these decisions should put any questions in writing to HMRC giving full details of their circumstances.
Disclosures unit
The address of the VAT Avoidance Disclosures Unit has changed and postal disclosures of notifiable schemes should now be sent to: VAT Avoidance Disclosures Unit, Anti-Avoidance Group (Intelligence), HMRC, 1st Floor, 22 Kingsway, London WC2B 6NR.
To allow businesses a reasonable period of time to adjust their processes to meet this change, disclosures made to the current postal address will continue to be accepted as validly made where the relevant affected accounting period starts before or during February 2006.
Disclosures can continue to be made by email to: vat.avoidance.disclosures.bst@hmrc.gsi.gov.uk.
