Article 6 can potentially apply to underlying assessments with concomitant penalties (which are criminal under the convention no matter how small). See para 62:
http://financeandtax.decisions.tribunals.gov.uk/judgmentfiles/j10807/TC0...
Article 6 can potentially apply to underlying assessments with concomitant penalties (which are criminal under the convention no matter how small). See para 62:
http://financeandtax.decisions.tribunals.gov.uk/judgmentfiles/j10807/TC0...