Revenue and Customs v Sippchoice Ltd (INCOME ) [2017] UKUT 87 (TCC) (1 March 2017)
INCOME TAX – scheme sanction charges – FA 2009 s 269 – whether
scheme administrator reasonably believed that no unauthorised payment
was being made – s 268(7)(a) – whether FTT erred in its interpretation and
application of the test of reasonableness – Mobilx considered – whether FTT
made an error of law in its findings of fact – Edwards v Bairstow
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