The WLR Daily case summaries
[2021] WLR(D) 506
Court of Appeal
Sheiling Properties Ltd v Revenue and Customs Commissioners
[2021] EWCA Civ 1425
2021 June 15;
Oct 5
Oct 5
King, Henderson, Arnold LJJ
Revenue— Income tax— Tax avoidance— Revenue making determination company liable to pay tax due under PAYE regulations and issuing accelerated payment notices pending company’s appeal against determination— Revenue subsequently issuing penalty notices— Whether determination made under PAYE regulations falling within statutory scheme for accelerated payment notices— Whether determination under PAYE regulations being “assessment” to tax— Whether “disputed tax”—
Taxes Management Act 1970 (c 9), ss 31, 55
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Finance Act 2014 (c 26), ss 203, 219, 221(3)
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Income Tax (Pay As You Earn) Regulations 2003 (SI 2682/2003), reg 80