Gallaher Limited v The Commissioners for HM Revenue and Customs [2020] UKUT 0354 (TCC)

The Upper Tribunal Tax and Chancery decision of Mr Justice Miles and Judge Greenbank on 26, 27 and 28 October 2020

Read the full decision in Gallaher Limited v HM Revenue [2020] UKUT 0354 (TCC)

CORPORATION TAX – whether the UK legislation in relation to intra-group disposals is compliant with EU law – the applicable freedoms, whether or not the provisions in question restrict a freedom – whether or not any restriction can be justified –proportionality of restrictions – conforming interpretation and disapplication – consideration of movements of capital – whether to refer questions of EU law to the Court of Justice of the European Union

Updates to this page

Published 14 December 2020