R (on the application of Aozora GMAC Investment Ltd) v Revenue and Customs Commissioners

Income tax – Double taxation relief. The defendant Revenue and Customs Commissioners' international manual INTM151060 had contained the representation that the Income and Corporation Taxes Act 1988 s 793A(3) had application only to the circumstances set out in art 24(4)(c) of the UK/USA Double Taxation Convention, which had no relevance to the claimant. However, the Administrative Court, in dismissing the claimant taxpayer's application for judicial review of the Revenue's issue of closure notices denying it relief, held that the claimant had not relied on that guidance.

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