Following a number of recent decisions clarifying the limits of the tribunal’s jurisdiction on a statutory appeal in the wake of Oxfam, it may be thought that there is nothing to be gained from maintaining a statutory appeal if HMRC considers that the proper route is an application for judicial review and the taxpayer is still in time to make one. However, abandoning a statutory appeal in these circumstances is not a decision to be taken lightly. There may be significant financial consequences in terms of the amount of interest due and the time for paying any substantive tax liabilities
