The Resource McCabe v Revenue and Customs Commissioners [2019] : UKFTT 317 (TC)

McCabe v Revenue and Customs Commissioners [2019] : UKFTT 317 (TC)

Label
McCabe v Revenue and Customs Commissioners [2019] : UKFTT 317 (TC)
Title
McCabe v Revenue and Customs Commissioners [2019] : UKFTT 317 (TC)
Contributor
Subject
Language
eng
Summary
Judgment by the First-tier Tribunal (Tax Chamber) judgment date 20 May 2019. The taxpayer, a UK national, had issued self-assessment tax returns in which he declared to be a resident of Belgium. Following inquiries into his tax returns, the UK tax authorities concluded that he was a resident of the United Kingdom. His tax returns were amended accordingly, and tax was imposed on his income and capital as a UK resident. The taxpayer was contending that he was a resident of Belgium, and a MAP with the Belgian tax authorities had failed to resolve the issue based on the tie-breaker provisions relating to residence. The taxpayer in a subsequent First-tier Tribunal case concerning his residence sought disclosure of the position paper of the UK tax authorities during the MAP as he alleged that they had taken a contradictory position to the one they were taking in the Tribunal hearing. The Tribunal concluded that it had power to order disclosure of the documents, but a discretion whether or not to do so
Citation source
In: International tax law reports. - London. - Vol. 21 (2019), part 6 ; p. 783-800
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/relatedWorkOrContributorName
Baker, P
http://library.link/vocab/subjectName
  • case law
  • disclosure
  • MAP
  • tax transparency
  • residence
  • tax treaty
  • tie-breaker rule
Label
McCabe v Revenue and Customs Commissioners [2019] : UKFTT 317 (TC)
Instantiates
Publication
Label
McCabe v Revenue and Customs Commissioners [2019] : UKFTT 317 (TC)
Publication

Library Locations

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      52.3736660 4.9336932
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