UT (Tax & Chancery) UT/2022/000103 - [2024] UKUT 00183 (TCC)

Fecha: 13-Mar-2024

Conclusions

Conclusion

97.

For the reasons given above we do not consider that the FTT made any error of law in the Decision in concluding:

(1)

that HMRC were not barred by acquiescence or otherwise estopped from applying to strike out the Claim Appeal; and

(2)

that TTSL was estopped, either by way of issue estoppel or cause of action estoppel, from bringing the Claim Appeal.

98.

The FTT was therefore right to strike out the part of TTSL’s appeal which related to the Overlap Period and we dismiss this appeal.

MR JUSTICE MICHAEL GREEN

JUDGE JONATHAN CANNAN

RELEASE DATE: 20 June 2024