HMRC v Charlton & Corfield
| Jurisdiction | UK Non-devolved |
| Judgment Date | 2012 |
| Neutral Citation | [2012] UKFTT 770 |
| Date | 2012 |
| Year | 2012 |
| Court | First-tier Tribunal (Tax Chamber) |
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17 cases
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Sanderson v Revenue and Customs Commissioners
...This argument failed before the Upper Tribunal having regard to what was said about the meaning of "discover" by the Upper Tribunal in Charlton v HMRC [2013] STC 866 and the point is not pursued on this appeal. But Mr Gordon (for Mr Sanderson) contends that "discover" and "be aware" in s.29......
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The Commissioners for HM Revenue and Customs v Raymond Tooth
...a “discovery” is correctly set out in this first passage from the decision of the UT in Charlton & others v RCC [2012] UKUT 770 (TCC); [2013] STC 866 at [37], where the tribunal said: “37. In our judgment, no new information, of fact or law, is required for there to be a discovery. All tha......
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David Stephen Sanderson v The Commissioners for HM Revenue and Customs
...of the TMA.) 21. Guidance as to what the word “discover” means in this context is to be found in Charlton v HMRC [2012] UKFTT 770 (TCC), [2013] STC 866. In that case, the Upper Tribunal (Norris J and Judge Berner) said this (at “In our judgment, no new information, of fact or law, is requir......
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JJ Manangement LLP v The Commissioners for HM Revenue and Customs
...There must be more than suspicion, and a threshold must be crossed, although there need not be a “eureka moment”: ibid, Charlton v HMRC [2012] UKFTT 770 (a decision of the Upper Tribunal, despite the neutral citation) at [24]–[28], Hicks v HMRC [2018] UKFTT 0022 (TC) at [51]. (3) Since it ......
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