First Alternative Medical Staffing Ltd and another v Revenue and Customs Commissioners

JurisdictionEngland & Wales
CourtCourt of Appeal (Civil Division)
Judgment Date04 March 2022
Neutral Citation[2022] EWCA Civ 249
Year2022

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5 cases
  • 1st Alternative Medical Staffing Ltd v The Commissioners for HMRC
    • United Kingdom
    • First-tier Tribunal (Tax Chamber)
    • 7 November 2025
    ...the NAC as it has been definitively determined by the Court of Appeal (R (oao First Alternative Medical Staffing Ltd and another) v HMRC [2022] EWCA Civ 249) that the Appellant had not chosen to apply the NAC in the Relevant Period and was not entitled to do so retrospectively. In addition,......
  • Chelsea Cloisters Management Limited v The Commissioners for HMRC
    • United Kingdom
    • First-tier Tribunal (Tax Chamber)
    • 12 February 2025
    ...according to what would have been reasonably understood by the ordinarily sophisticated taxpayer. We were referred to First Alternative v HMRC [2022] EWCA Civ 249 and Murphy v HMRC [2023] EWCA Civ 497, [2023] STC 944. The dispute was as to how ESC 3.18 is to be 131. Mr Beal KC and Mr Lowent......
  • Mercy Global Consult Ltd ((in Liquidation)) v Mr Abayomi Adegbuyi-Jackson
    • United Kingdom
    • Chancery Division
    • 13 December 2023
    ...the concession cannot be operated retrospectively. The Court of Appeal so decided in First Alternative Medical Staffing Ltd v HMRC [2022] EWCA Civ 249. “…the short answer to this appeal is that the NAC would be understood by the ordinarily sophisticated taxpayer as requiring a choice to be ......
  • Thomas Holdings Limited & Ors, R (on the application of) v The Commissioners for HMRC
    • United Kingdom
    • King's Bench Division (Administrative Court)
    • 8 July 2025
    ...32, [2012] 1 AC 1 per Sir John Dyson SCJ at [30]; Davies at [29]; R (oao First Alternative Medical Staffing Ltd and anor) v Revenue and Customs [2022] EWCA Civ 249 per Zacaroli J at [34]; Murphy at (8) Given HMRC’s primary duty to collect tax, to the extent there is any doubt - either as to......
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