Decision Number: | TC 08456 |
Appellant: | ULSTER METALS |
Respondent: | Her Majesty's Revenue & Customs |
Chairmen / Special Commissioners: |
Dr Christopher MCNALL |
Date Of Decision: | 07/04/2022 |
Main Category: | PROCEDURE |
Main Subcategory: | Other |
Notes: | COSTS - Case allocated to complex category Costs of an interlocutory application - Costs awarded to HMRC on the basis of Rule 10(1)(c), but, if not, would have been awarded on the basis of unreasonable conduct (being a materially misleading witness statement, subsequently found to be untrue) under Rule 10(1)(b). Costs of a substantive hearing - Each party successful in part - Appeal allowed in relation to Revenue's failure to establish connection to fraud for one set of deals - Appeal dismissed in relation to other sets of deals, where the Appellant was found to have had actual knowledge of connection to fraud - No order as to costs. |