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Although GC Trading's appeal before the Special Commissioners had been successful (see Update, Taxation, 29 November 2007, page 582), further arguments were brought before the commissioner with regard to costs.
The appellant argued that it should be awarded costs on the basis that HMRC had acted 'wholly unreasonably in connection with the hearing'. The appellant claimed further that HMRC should not have proceeded with the original case at all, as it was a 'flagrant attempt to bully the taxpayer into submission'.
The Commissioner found that, on the contrary, HMRC had acted wholly reasonably in connection with the appeal, and their arguments had not been unreasonable. Having found that HMRC had acted reasonably, the Commissioner said he had no jurisdiction to award costs and dismissed the appeal with no order as to costs.
GC Trading Ltd (SpC 686)
