Adam Craggs and Constantine Christofi (RPC) examine the judgment and consider where this leaves us.
The High Court dismissed the claimants’ judicial review challenges in R (oaoRowe and Others) v HMRC [2015] EWHC 2293 (Admin) and R (oao Vital Nut Co Ltd) v HMRC [2016] EWHC 1797 (Admin) (reported in Tax Journal 12 January 2018). The claimants challenged the lawfulness of APNs/PPNs (the notices) which HMRC had issued to them pursuant to FA 2014 Part 4.
Permission to appeal was granted to the claimants. The Court of Appeal heard both appeals together and delivered its judgment on 12 December 2017. The leading judgments were given by Lady Justice Arden (grounds 1 to 4) and Lord Justice McCombe (grounds 5 and 6) who dismissed the appeals.
Grounds of appeal
The court considered six grounds of appeal. The claimants argued that the decision to issue the notices was:
...
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Adam Craggs and Constantine Christofi (RPC) examine the judgment and consider where this leaves us.
The High Court dismissed the claimants’ judicial review challenges in R (oaoRowe and Others) v HMRC [2015] EWHC 2293 (Admin) and R (oao Vital Nut Co Ltd) v HMRC [2016] EWHC 1797 (Admin) (reported in Tax Journal 12 January 2018). The claimants challenged the lawfulness of APNs/PPNs (the notices) which HMRC had issued to them pursuant to FA 2014 Part 4.
Permission to appeal was granted to the claimants. The Court of Appeal heard both appeals together and delivered its judgment on 12 December 2017. The leading judgments were given by Lady Justice Arden (grounds 1 to 4) and Lord Justice McCombe (grounds 5 and 6) who dismissed the appeals.
Grounds of appeal
The court considered six grounds of appeal. The claimants argued that the decision to issue the notices was:
...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
