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Atherton v Revenue and Customs Commissioners

Cited authorities 21 Cited in 34 Precedent Map Related
JurisdictionUK Non-devolved
Judgment Date12 February 2019
Neutral Citation[2019] UKUT 41 (TCC)
Date12 February 2019
CourtUpper Tribunal (Tax and Chancery Chamber)
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23 cases
  • Paya Ltd and Others
    • United Kingdom
    • First Tier Tribunal (Tax Chamber)
    • September 17, 2019
    ...of HMRC … [663] The UT has also accepted this concept of “newness” in Beagles v R & C Commrs [2018] BTC 528 and Atherton v R & C Commrs [2019] BTC 507. Since the hearing, the Court of Appeal has released a decision in the Tooth case (R & Commrs v Tooth [2019] BTC 14) in which, at [61], that......
  • Giuliani
    • United Kingdom
    • First Tier Tribunal (Tax Chamber)
    • June 28, 2021
    ...a tax advantage, but by his own admission had not fully read the notes when making his submissions. The FTT cited Atherton v R & C Commrs [2019] BTC 507, that “the reasonable care which should be taken by a taxpayer is assessed by reference to a prudent and reasonable taxpayer in the positi......
  • Hunter
    • United Kingdom
    • First Tier Tribunal (Tax Chamber)
    • May 14, 2019
    ...to avoid bringing about that loss or situation. Case law on discovery assessments [211] At paragraphs 10–15 of Atherton v R & C Commrs [2019] BTC 507 the Upper Tribunal summarised the principles on discovery assessments as follows: [10] Two important principles underpin the construction and......
  • Cumming-Bruce
    • United Kingdom
    • First Tier Tribunal (Tax Chamber)
    • December 4, 2020
    ...made the return, or in any accounts, statements or documents accompanying any such claim; … [109] At [10]–[60] of Atherton v R & C Commrs [2019] BTC 507 the Upper Tribunal summarised the principles on discovery assessments as follows: [10] Two important principles underpin the construction ......
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