UK Supreme Court 2

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Today in the UK Supreme Court 2, Lord Neuberger, Lord Kerr, Lord Reed, Lord Hughes and Lord Hodge will hear the case of R (on the application of de Silva and another) (Appellants) v Commissioners for Her Majesty's Revenue and Customs) (Respondent). At issue is Whether HMRC was entitled to enquire into the appellants' claims for loss relief otherwise than by opening an enquiry under Schedule 1A of the Taxes Management Act 1970, which is subject to a time limit that had elapsed prior to the date of the enquiry.