The House acknowledged the validity of pre-transaction rulings. Such rulings were of assistance both to the respondents and to the taxpayer. Lord Templeman referred to ‘[t]he trick of circular, self-cancelling payments with matching receipts and payments’.
Lord Browne-Wilkinson, Lord Mustill, Lord Templeman
[1994] 1 WLR 334
England and Wales
Cited by:
Cited – Stockler v HM Revenue and Customs ChD 22-Sep-2009
The taxpayer appealed against a decision confirming the Commissioners’ power to impose a penalty on him. It was said that his solicitors’ firm had negligently understated its profits. A settlement was proposed allowing a withdrawal of the return, . .
These lists may be incomplete.
Updated: 17 June 2021; Ref: scu.375141
