PHILLIP BRIAN HIGGS & OTHERS and THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2023] UKUT 00296 (TCC)
Upper Tribunal Tax and Chancery decision of JUDGE VINESH MANDALIA and JUDGE KEVIN POOLE on 13 December 2023
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Procedure – preliminary issue – marketed tax avoidance scheme – doctrine of precedent – the FtT does not have jurisdiction to consider whether a taxpayer was entitled to PAYE credits under Regulations 185 and 188 of the Income Tax (PAYE) Regulations 2003 for sums that end users were liable to deduct under PAYE.