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First-tier Tribunal (Tax) |
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You are here: BAILII >> Databases >> First-tier Tribunal (Tax) >> Revenue & Customs v SMARTPAY LIMITED (Disclosure of tax avoidance schemes - Whether the arrangements were notifiable arrangements - Whether the Respondents were promoters) [2022] UKFTT 146 (TC) (03 May 2022) URL: http://www.bailii.org/uk/cases/UKFTT/TC/2022/TC08477.html Cite as: [2022] STI 821, [2022] SFTD 1010, [2022] UKFTT 146 (TC) |
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| Decision Number: | TC 08477 |
| Appellant: | THE COMMISSIONERS FOR HER MAJESTY'S REVENUE AND CUSTOMS |
| Respondent: | (1) SMARTPAY LIMITED (incorporated in the UK) (2) SMARTPAY LIMITED (incorporated in the Isle of Man) |
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Chairmen / Special Commissioners: |
Asif MALEK |
| Date Of Decision: | 03/05/2022 |
| Main Category: | PROCEDURE |
| Main Subcategory: | Other |
| Notes: | Disclosure of tax avoidance schemes - Whether the arrangements were notifiable arrangements - Whether the Respondents were promoters - Finance Act 2004 ss 306, 307- The Tax Avoidance Schemes (Prescribed Descriptions of Arrangements) Regulations 2006, SI 2006/1543 reg 8 - HMRC v Curzon Capital Ltd [2019] UKFTT 63 & HMRC v Hyrax Resourcing Ltd & Ors [2019] UKFTT 175 considered. |
