PROCEDURE – personal liability notice – FA 2007, Sch 24, para 19 – application of Article 6 of the European Convention on Human Rights – appellant’s application for a stay – whether HMRC’s decision to proceed by way of civil penalty an abuse of process – inability to obtain a representation order – whether standard of proof should be the criminal standard – HMRC’s application to strike out parts of appellant’s grounds of appeal for abuse of process in seeking to re-litigate matters the subject of earlier appeals by the company – application to admit into evidence a prior tribunal decision
Citations:
[2016] UKFTT 781 (TC)
Links:
Jurisdiction:
England and Wales
Human Rights, Taxes Management
Updated: 29 January 2022; Ref: scu.573949