PERCIVAL v HMRC

摘要

Mr Percival, a former Inland Revenue officer, moved to Ireland in 2004. In 2006, he began to receive a civil service pension, which was taxed in the UK in accordance with the Double Taxation Agreement between the UK and the Irish Republic. In 2009, he appealed to the FIT (Kenneth Percival v HMRC UKFTT/TC/2013/TC02654) on the basis that this was unfairly discriminatory, in contravention of EU law, and that his liability to UK tax should be limited to the tax that would have been suffered by an Irish national in his circumstances.