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Sisyphean struggle
KEY POINTS
- The taxpayer restructured his business to mitigate his VAT liabilities.
- The First-tier Tribunal asked itself the wrong questions.
- The CJEU focused on whether the arrangements reflected economic reality.
- The Court of Appeal remitted the case to the First-tier Tribunal.
- Relocating a business should not inevitably be characterised as an abuse of law.
- The ghost of Halifax continues to haunt taxpayers.
Sisyphus was punished for his craftiness in avoiding death by being condemned to repeatedly to roll a boulder up a hill only for it roll down again as soon as he had reached the summit.
After the Court of Appeal’s judgment in CRC v P...
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