- Corporation tax on restitution interest (British American Tobacco v HMRC)
- Original news
- What are the practical implications of this case?
- What was the case about?
- What were the taxpayer’s arguments?
- What did the FTT decide on EU legal principles?
- Principle of effectiveness
- Principles of legal certainty and legitimate expectation
- Other EU principles
- What did the FTT decide on the human rights arguments?
- Right to a fair hearing and effective remedy
- Right to and protection of property
- Case details
Tax analysis: The First-tier Tax Tribunal (FTT) has dismissed British American Tobacco’s appeal against the deduction by HMRC of withholding tax under the special corporation tax rules, introduced in 2015, applying to restitution interest. The FTT found that the rules were compatible both with EU legal principles and with the taxpayer’s fundamental human rights.
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