[2012] UKUT 261 (TCC).

Upper Tribunal (Tax and Chancery Chamber).

Judge Timothy Herrington.

Decision released 20 July 2012.

Income tax – Schedule E – Pension fund transfer – Reciprocal arrangements for transfer between UK and Guernsey – Transfer held to be unauthorised – Taxpayers liable for income tax on payments – First-tier Tribunal having no jurisdiction to waive interest payable – HMRC's appeal allowed – Taxes Management Act 1970, s. 86 – Income and Corporation Taxes Act 1988, s. 647.

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