The WLR Daily case summaries
[2023] WLR(D) 220
Court of Appeal
Rex (Murphy and another) v Revenue and Customs Commissioners
[2023] EWCA Civ 497
2023 April 20; May 15
Newey, Andrews,Falk LJJ
Revenue— Extra-statutory concession— Time limit— Non-UK resident trust having paid tax on income subsequently distributed to UK resident beneficiary— Beneficiary seeking credit as to tax ostensibly due, relying on extra-statutory concession by revenue (ESC B18)— Whether six-year time limit applying to claim for credit by reference to such concession