E Buyer UK Limited v The Commissioners for HM Revenue and Customs and The Commissioners for HM Revenue and Customs v Citibank NA: [2016] UKUT 0123 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Nugee and Judge Herrington on 10 March 2016.

• From: HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
• Published: 1 December 2016

• Category: Tax
• Release date: 10 March 2016

Read the full decision in E Buyer UK Limited v The Commissioners for HM Revenue and Customs and The Commissioners for HM Revenue and Customs v Citibank NA: [2016] UKUT 0123 (TCC).

PROCEDURE – MTIC appeals - allegations of knowledge that appellant’s transactions orchestrated and contrived and formed part of an overall scheme to defraud the Revenue - whether HMRC’s statement of case alleged dishonesty and therefore whether sufficiently particularised - whether standard disclosure of relevant documents appropriate.

Published 1 December 2016