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Error al cargar el documento
- Heading
- Introduction
- Background
- Ground 1 – Breach of Padfield principle
- Ground 2 - Misdirections of law and Wednesbury irrationality
- Remedy sought
- Parties’ submissions in summary
- Issues
- Misdirection that exercise of 7A premature because quantum of liability not established
- Misdirection and/or irrelevant consideration as to interaction between NICS and 7A
- Mistaken premise that UBS would not and/or could not be compelled to provide information relating to HMRC’s enquiries
- Does the combination of above factors mean that HMRC are bound to exercise the 7A discretion?
- Conclusions