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Sitting in public at the Royal Courts of Justice, London on 14-16 & 19 November 2018
Kevin Prosser QC and Barbara Belgrano, counsel, instructed by Stephenson Harwood LLP, for the First Referrer
Michael Gibbon QC, Richard Vallat QC and Ronan Magee, counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs, for the Second Referrers
This decision addresses a joint referral by the parties to the Tribunal for determination of a question arising in the course of an enquiry into the corporation tax self-assessment returns of the First Referrer (�Inmarsat�) for the accounting period ended 31 December 1999 and subsequent periods.
The question (and the surrounding factual circumstances to which it relates) are set out in full below, but in essence the issue is as follows.
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Common Room
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