[2017] EWHC 1055 (Admin)

High Court (Queenʼs Bench Division)

The Honourable Mr. Justice Ouseley

Judgment delivered 9 May 2017

UK/Swiss confederation – Taxation cooperation agreement – One-off payment to clear past unpaid tax liabilities – Claimant failed to act when warned by bank of one-off payment – Voluntary disclosure of Swiss accounts made later – Claim that HMRC should repay difference between the one-off payment and tax, penalties and interest due – Dismissed – Finance Act 2012 (‘FA 2012’), Sch. 36.

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