Cobalt Data Centre 2 LLP and Cobalt Data Centre 3 LLP v The Commissioners for HM Revenue and Customs:[2019] UKUT 0342 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Zacaroli and Judge Richards on 15 November 2019.
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.INCOME TAX– Whether appellants entitled to enterprise zone allowances – whether appellants carrying on a business with a view to profit – whether appellants had a legitimate expectation that HMRC would apply practice set out in correspondence.