The First-tier Tribunal did not err in law in deciding that the appellant’s entitlement to a PAYE credit under the PAYE regulations was not within its jurisdiction, that discovery assessments raised by HMRC were valid, and in relation to the ‘transfer of assets abroad’ provisions that: (a) the motive defence was not available; and (b) the TOAA charge was not unlawful under EU law.
Summary
The First-tier Tribunal (FTT) did not err in law in deciding that the appellant’s entitlement to a PAYE credit under the PAYE regulations was not within its jurisdiction, that discovery assessments raised by HM Revenue and Customs (HMRC) were valid, and in relation to the ‘transfer of assets abroad’ (TOAA) anti-avoidance provisions that: (a) the motive defence was not available; &
