(1) Redevco Properties UK 1 Ltd (Appellant) v The Commissioners for HMRC (Respondent) (2) The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Nos. 1 to 4 (Appellant) v The Commissioners for HMRC (Respondent)
Tuesday 21 – Thursday 23 April 2026
(1 and 2) By Appellant’s Notice filed on 10 February 2025 the Appellant appeals a decision of the Upper Tribunal delivered on 8 October 2024.
These joined appeals concern the compatibility of the UK legislation on company and trustee migrations with EU law and whether the UK legislation requiring immediate payment of corporation tax can be subject to a deferred payment of the charges.
Dismissing the taxpayers’ appeals, the Upper Tribunal has held that, where a taxpayer’s right of freedom of establishment would otherwise be infringed, it includes an option to defer payment of the exit tax in five equal annual instalments.
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Day 1
Day 2
Day 3