The Queen on the Application of Telefonica Europe Plc and Telefonica UK Limited v The Commissioners for HM Revenue and Customs: [2016] UKUT 0173 (TCC)

Upper Tribunal Tax and Chancery decision of Mrs Justice Rose and Judge Sinfield on 15 April 2016.

From:
HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
Published
1 December 2016
Category:
Tax
Release date:
15 April 2016

Read the full decision in .

JUDICIAL REVIEW 鈥� determining place of effective use and enjoyment of telecommunications services - whether methodology for apportioning charge between EU and non-EU services based on usage is unlawful 鈥� whether claimants had legitimate expectation derived from correspondence with HMRC that claimants could continue to use methodology based on revenues until change in law or claimant鈥檚 business 鈥� whether HMRC had duty to consult claimants before requiring them to apply a new methodology 鈥� whether HMRC consulted claimants adequately.

Updates to this page

Published 1 December 2016