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Mr Mciver’s submissions on behalf of HMRC
Mr Mciver’s submissions on behalf of HMRC
Mr Mciver put forward numerous reasons why the Application should not be granted, either in its original form or in line with Smart Price, each of which is considered below.
- Heading
- Introduction
- The law
- Liability to excise duty
- The burden of proof
- Judicial review
- Disclosure
- The Application
- Mr Thornton’s submissions on behalf of UWG
- Mr Mciver’s submissions on behalf of HMRC
- Disclosure was inappropriate in principle?
- UWG failed to carry out appropriate checks?
- Judicial review
- Scope too wide/fishing expedition?
- Disproportionate?
- Particular supplies?
- Not fair and just?
- Flaws in the Application?
- Conclusions