THE KING (on the application of) UBS AG v THE COMMISSIONERS FOR HIS MAJESTY바카라 사이트™S REVENUE AND CUSTOMS and JONATHAN WOOD [2024] UKUT 00242 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Swami Raghavan and Judge Jeanette Zaman on 21 August 2024
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JUDICIAL REVIEW 바카라 사이트“ challenge to HMRC바카라 사이트™s refusal to exercise s684(7A) ITEPA discretion to remove obligation on employer to account for PAYE in respect of employee바카라 사이트™s tax liability on earnings in the form of gilts 바카라 사이트“ HMRC subsequently withdrew defence and sought consent to withdraw from proceedings on basis that a new HMRC officer would make new decision on exercise of discretion 바카라 사이트“ whether HMRC correct to say original action rendered academic 바카라 사이트“ no 바카라 사이트“ whether tribunal should make mandatory, declaratory and quashing orders sought by claimant 바카라 사이트“ no (apart from declaratory relief in respect of misdirections of law that were made out and mandatory order to make a new decision)