The Commissioners for HM Revenue and Customs v Volkerrail Plant Limited, Volkerrail Power Limited, VolkerFitxPatrick Limited, Volkerrail Limited [2022] UKUT 00078 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Roth and Judge Jonathan Richards on 07 March 2022
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CORPORATION TAX – Whether s403D(1)(c) of ICTA constitutes unlawful restriction on freedom of establishment – yes because, while justified, it operates disproportionately – conforming interpretation adopted – appeal allowed