高級稅務法庭駁回了英國稅務海關總署對Hitchins案的上訴，在該案中，一級稅務法庭指示英國稅務海關總署停止對三兄弟及其已故父親創立的百慕大公司的稅務事務進行調查。英國稅務海關總署認為，FTT 在接受納稅人對海外資產轉移立法的解釋時犯了錯誤。然而，高級稅務法庭同意FTT的裁決，認為它「平衡了各種因素，並得出結論認為調查被過度拖延，應該結束」。因此，HMRC 的上訴被駁回（HMRC v Hitchins, 2024 UKUT 114 TCC）。

TRUSTS: HMRC loses appeal in transfer of assets abroad case

The Upper Tax Tribunal has rejected HMRC appeal in the Hitchins case, in which the First-tier Tax Tribunal directed HMRC to cease its inquiries into the tax affairs of three brothers and the Bermuda company founded by their late father. HMRC argued that the FTT had erred in accepting the taxpayers' interpretation of the transfer of assets abroad legislation. However, the Upper Tax Tribunal agreed with the FTT's ruling, finding it had 'balanced the various factors, and concluded that the enquiry had been unduly prolonged and should be brought to a close'. Accordingly, HMRC's appeal was dismissed (HMRC v Hitchins, 2024 UKUT 114 TCC).

Sources:
BAILII
Upper Tax Tribunal (full decision, PDF)