R & C Commissioners v Root2 Tax Ltd

JurisdictionUK Non-devolved
Judgment Date20 December 2022
Neutral Citation[2022] UKUT 353 (TCC)
CourtUpper Tribunal (Tax and Chancery Chamber)
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2 cases
  • The Commissioners of HM Revenue and Customs v Root2 Tax Limited [2022] UKUT 00353 (TCC)
    • United Kingdom
    • Upper Tribunal (Tax and Chancery Chamber)
    ...[2022] UKUT 00353 (TCC) Case Number: UT-2022-000003 UPPER TRIBUNAL (Tax and Chancery Chamber) Rolls Building Fetter Lane London EC4A 1NL Part 7 Finance Act 2004 – DOTAS provisions – notifiable arrangements – section 308 FA 2004 – duties of promoter – whether duty to notify arises on each im......
  • The Commissioners for HMRC v IPS Progression Limited
    • United Kingdom
    • First-tier Tribunal (Tax Chamber)
    • February 12, 2024
    ...the very last day of the time limit under s 103(4) TMA for doing so. (iv) The decision of the Upper Tribunal in Revenue And Customs v Root2 Tax Ltd [2022] UKUT 353 (TCC), [2023] STC 171 (“Root 2”), on which the Respondent relies, was published on 20 December such that the Respondent should ......

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