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Court of Appeal finds for HMRC in 'derivative disregard' case (Bristol and West plc v HMRC)

Court of Appeal finds for HMRC in 'derivative disregard' case (Bristol and West plc v HMRC)
Published on: 29 April 2016
Published by: LexisPSL
  • Court of Appeal finds for HMRC in 'derivative disregard' case (Bristol and West plc v HMRC)
  • Original news
  • What was this case about?
  • What did the court decide?
  • What should tax lawyers take note of?

Article summary

Tax analysis: The Court of Appeal has found in HMRC’s favour in a long-running case where millions of pounds of tax was at stake. The court dismissed the taxpayer’s appeal and decided that a disregard provision in the derivative contract rules could only apply to a novation between group companies if both companies were subject to the rules. The court allowed HMRC’s cross-appeal and decided that a valid closure notice had not been issued by HMRC when looked at in its objective factual context. or take a trial to read the full analysis.

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