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C6a. Double taxation relief claims

Existence of enquiry is a question of law

 

“the question as to whether the steps that HMRC took in response to the claim amount to an “enquiry”…is a question of law” (Portland Gas Storage Ltd v. HMRC [2014] UKUT 0270 (TCC), §38)

 © 2026 by Michael Firth KC, Gray's Inn Tax Chambers

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