(1) GLL BVK International Immobilien Spezialfonds (2) iii-BVK Europa Immobilien Spezialfonds v The Commissioners for HM Revenue and Customs: [2019] UKUT 0017 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Richards and Judge Thomas Scott on 23 January 2019.
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INCOME TAX – claims for repayment of tax paid by German real estate investment funds under the Non-Resident Landlord scheme – whether original claim for all income tax or only a proportion – if not, whether claim could be amended under TMA s114 – application to amend claim under Rule 5(3)(c) of FTT Rules – whether FTT could direct repayment of a greater sum than was claimed under TMA s50 or Schedule 1A – appeal dismissed.
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Published 23 January 2019