VALUE ADDED TAX – 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 instead of a criminal prosecution an abuse of process – whether standard of proof should be the criminal standard – application to admit into evidence a prior tribunal decision.
[2020] UKUT 212 (TCC)
Bailii
England and Wales
Updated: 17 June 2021; Ref: scu.652566 br>