HMRC’s powers
HMRC’s powers
Section 5:
“(1) The Commissioners shall be responsible for: … the collection and management of revenue for which the Commissioners of Customs and Excise were responsible before the commencement of this section …”
Section 9:
“(1) The Commissioners may do anything which they think:
(a) necessary or expedient in connection with the exercise of their functions, or
(b) incidental or conducive to the exercise of their functions.”
Interpretation Act 1978 (IA)
Section 11:
“Where an Act confers power to make subordinate legislation, expressions used in that legislation have, unless the contrary intention appears, the meaning which they bear in the Act.”
Section 12:
“(1) Where an Act confers a power or imposes a duty it is implied, unless the contrary intention appears, that the power may be exercised, or the duty is to be performed, from time to time as occasion requires. …”
- Heading
- Introduction
- Brief overview of SDIL
- FA17
- Notice 2 – SDIL returns and records (part of which has force of law)
- HMRC’s powers
- Agreed facts
- Overview of relevant documents
- Parties’ submissions
- Appellant’s submissions
- HMRC’s submissions
- Discussion
- Our view on statutory infrastructure
- Appellant’s entitlement to SDIL credits
- Withdrawal of credits
- Efficacy of the Assessments
- Conclusions
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