The First De Sales Ltd Partnership and Others v Revenue and Customs Commissioners

JurisdictionUK Non-devolved
Judgment Date27 November 2018
Neutral Citation[2018] UKUT 396 (TCC)
Date27 November 2018
CourtUpper Tribunal (Tax and Chancery Chamber)
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22 cases
  • R Christopher Mitchell v Commissioners for HM Revenue and Custom
    • United Kingdom
    • Queen's Bench Division (Administrative Court)
    • 17 December 2020
    ...Chamber) (Carr J and Judge Sinfield) dismissed the taxpayers' appeal on 27 November 2018: First De Sales Limited Partnership v HMRC [2018] UKUT 0396 (TCC). In the course of doing so it said that the facts the judge had set out were uncontroversial and there was no challenge to them on the ......
  • Bluecrest Capital Management (UK) LLP v The Financial Conduct Authority [2023] UKUT 00140 (TCC)
    • United Kingdom
    • Upper Tribunal (Tax and Chancery Chamber)
    • Invalid date
    ...Ltd (t/a Openair) v Opal Telecom Ltd [2009] EWHC 339 (Ch) at [15]; (as cited in The First De Sales Partnership and others v HMRC [2018] UKUT 396 (TCC) at [33]). One of the principles set out in Easyair concerned the proper approach of the Court when considering strike out based on a point o......
  • British Telecommunications PLC v The Commissioners for HM Revenue and Customs [2023] UKUT 00122 (TCC)
    • United Kingdom
    • Upper Tribunal (Tax and Chancery Chamber)
    • Invalid date
    ...that are not fit for a full hearing at all. 69. The Upper Tribunal amplified this guidance in First de Sales Limited Partnership v HMRC [2019] 4 WLR 21. The tribunal cited the judgment of Lewison J (as he then was) in Easyair Limited v Opal Telecom [2009] EWHC 339 and stated as follows at [......
  • The First De Sales Limited Partnership and Others v The Commissioners for HM Revenue and Customs
    • United Kingdom
    • Upper Tribunal (Tax and Chancery Chamber)
    • 27 November 2018
    ...[2018] UKUT 0396 (TCC) Appeal number: UT/2018/0056 UT/2018/0057 UT/2018/0058 UT/2018/0059 PROCEDURE – application to strike out – whether appeals have a reasonable prospect of success - construction of section 225 ITEPA 2003 - whether FTT wrong to conclude that, on evidence available, appel......
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