The Queen on the Application of Telefonica Europe Plc and Telefonica UK Limited v The Commissioners for HM Revenue and Customs: [2016] UKUT 0173 (TCC)
Upper Tribunal Tax and Chancery decision of Mrs Justice Rose and Judge Sinfield on 15 April 2016.
Read the full decision in .
JUDICIAL REVIEW – determining place of effective use and enjoyment of telecommunications services - whether methodology for apportioning charge between EU and non-EU services based on usage is unlawful – whether claimants had legitimate expectation derived from correspondence with HMRC that claimants could continue to use methodology based on revenues until change in law or claimant’s business – whether HMRC had duty to consult claimants before requiring them to apply a new methodology – whether HMRC consulted claimants adequately.
Updates to this page
Published 1 December 2016