Glencore Energy UK Ltd & Anor v Revenue & Customs (Procedure - Diverted Profits Tax and Corporation Tax appeals) [2019] UKFTT 438 (TC)
[1]The above appeals shall be stayed in accordance with Rule 5(3)(j) of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 and the Tribunal’s case management powers (“the Stay”).[2]The Stay is directed for the purpose of enabling a mutual agreement procedure (“MAP”) to occur between the UK and Swiss Competent Authorities pursuant to Article 24 of the Switzerland – United Kingdom Income Tax Treaty 1977 (“the Treaty”).[3]The Stay shall continue until the final outcome of the MAP (including any arbitration pursuant to Article 24(5) of the Treaty).[4]Direction 3, above, is subject to any application in the meantime by any party to lift the Stay. Reasons[5]See the decision issued to the parties separately from, but at the same time as these directions. JOHN BROOKS TRIBUNAL JUDGE RELEASE DATE: 05 JULY 2019