16 August 2006
Categories:
Tax cases
They have the power
The taxpayer company applied to the Special Commissioners for a direction to HMRC to issue a closure notice in respect of an enquiry into the company's tax return. The Commissioners decided that they should refer certain questions relating to controlled foreign companies to the European Court of Justice. HMRC appealed to the High Court, saying that the Commissioners did not have the power to make these referrals. The appealed was dismissed, so HMRC appealed.
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