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You are here: BAILII >> Databases >> England and Wales High Court (Administrative Court) Decisions >> Mitchell, R (On the Application Of) v Commissioners for Her Majestys Revenue And Custom [2020] EWHC 3489 (Admin) (17 December 2020) URL: https://www.bailii.org/ew/cases/EWHC/Admin/2020/3489.html Cite as: [2020] EWHC 3489 (Admin), [2021] BTC 2, [2020] WLR(D) 692, [2021] WLR 1427, [2021] 1 WLR 1427 |
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QUEEN'S BENCH DIVISION
ADMINISTRATIVE COURT
Strand, London, WC2A 2LL |
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B e f o r e :
Sitting as a judge of the High Court
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The Queen on the application of CHRISTOPHER ![]() | Claimant |
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- and - |
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COMMISSIONERS FOR HER MAJESTYS REVENUE AND CUSTOM |
Defendant |
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MARIKA LEMOS (instructed by HMRC)
for the Defendant
Hearing dates: 10 December 2020
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VERSION
OF JUDGMENT
Crown Copyright ©
SIR ROSS CRANSTON:
Introduction
Background
Finance Act 2020; section 12ABZAA of 1970 Act
Upper Tribunal determination in Inverclyde
Ground 1
Ground 2
Delay
Conclusion
Note 1 Section 118(1) of the 1970 Act provides that in this Act, unless the context otherwise requires, "the Taxes Acts" means this Act and (a) the Tax Acts and (b) the Taxation of Chargeable Gains Act 1992 and all other enactments relating to capital gains tax. [Back]