Harrison News Ltd v Revenue & Customs [2011] UKFTT 251 (TC) (15 April 2011)
The Tribunal held that HMRC’s Regulation 80 determinations and Section 8 decisions were reasonably made based on available information, and the Appellant failed to provide any evidence to refute the assessments despite ample opportunity. The appeal was dismissed and the assessments confirmed.
- Citation
- [2011] UKFTT 251
- Parties
- Appellant: Harrison News Ltd; Respondents: The Commissioners for Her Majesty’s Revenue and Customs
- Jurisdiction
- United Kingdom
- Judgment Date
- 15 April 2011
- Procedural Posture
- Appeal / Final Decision at First Tier Tribunal (tax)
- Outcome
- Appeal dismissed
- Legal Topics
- PAYE Determinations, National Insurance Contributions, Income Tax, Corporation Tax, Appeal Procedure, Burden of Proof
Case Brief
Summary, issues, holding and outcome
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Parties
Harrison News Ltd
Appellant
The Commissioners for Her Majesty’s Revenue and Customs
Respondents
Procedural Posture
Appeal / Final Decision at First Tier Tribunal (tax)
Legal Issues
- 1 Whether Regulation 80 determinations and Section 8 decisions by HMRC were valid and reasonable
- 2 Whether HMRC provided adequate breakdown of assessed amounts
- 3 Whether Appellant provided sufficient evidence of reimbursement or error in assessments
Ratio Decidendi
The Tribunal held that HMRC’s Regulation 80 determinations and Section 8 decisions were reasonably made based on available information, and the Appellant failed to provide any evidence to refute the assessments despite ample opportunity. The appeal was dismissed and the assessments confirmed.
Court Disposition
Appeal dismissed
Orders
- Regulation 80 assessments and Section 8 decisions confirmed in the stated amounts
- Right to apply for permission to appeal within 56 days
Full Case Text
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