The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Numbers 1 to 4 & Anor v The Commissioners for HMRC
Upper Tribunal held the UK exit-tax payment rules could be read to allow five annual instalments, but it erred in excluding interest.
- Exit tax
- Freedom of establishment
- Conforming interpretation
- Retrospective effect
- Legal certainty
- Capital gains tax