R & C Commissioners v Hotel La Tour Ltd

JurisdictionUK Non-devolved
CourtUpper Tribunal (Tax and Chancery Chamber)
Judgment Date24 July 2023
Neutral Citation[2023] UKUT 178 (TCC)
Year2023

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3 cases
  • Commissioners for HM Revenue and Customs v Hotel La Tour Ltd
    • United Kingdom
    • Court of Appeal (Civil Division)
    • 21 May 2024
    ...Lady Justice Whipple Introduction 1 This is HMRC's appeal against the decision of the Upper Tribunal (Zacaroli J and Judge Guy Brennan) [2023] UKUT 00178 (TCC), which dismissed HMRC's appeal against the decision of the First-tier Tribunal (Judge Richard Chapman KC and Ms Gill Hunter) [2021]......
  • Commissioners for His Majesty's Revenue and Customs (Respondent) v Hotel La Tour Ltd (Appellant)
    • United Kingdom
    • Supreme Court
    • 17 December 2025
    ...paras 52–53. 42. HMRC appealed but the Upper Tribunal (Tax and Chancery Chamber) (Zacaroli J and Judge Brannan) dismissed the appeal: [2023] UKUT 178 (TCC) (24 July 2023). They upheld the FTT’s analysis that because the share sale was a fund-raising transaction, the direct and immediate lin......
  • Commissioners for His Majesty's Revenue and Customs (Respondent) v Hotel La Tour Ltd (Appellant)
    • United Kingdom
    • Supreme Court
    • 17 June 2024
    ...paras 52–53. 42. HMRC appealed but the Upper Tribunal (Tax and Chancery Chamber) (Zacaroli J and Judge Brannan) dismissed the appeal: [2023] UKUT 178 (TCC) (24 July 2023). They upheld the FTT’s analysis that because the share sale was a fund-raising transaction, the direct and immediate lin......