Harrison News Ltd v Revenue & Customs [2011] UKFTT 251 (TC) (15 April 2011)

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

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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)

  1. 1 Whether Regulation 80 determinations and Section 8 decisions by HMRC were valid and reasonable
  2. 2 Whether HMRC provided adequate breakdown of assessed amounts
  3. 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