Jeanette Zaman and Zoe Andrews (Slaughter and May) review recent developments affecting the City.
Judicial review
Several recent judicial review cases demonstrate the uphill battle taxpayers face in seeking to challenge actions taken by HMRC on public law grounds.
Dickinson: accelerated payment notices (APNs)
J Dickinson v HMRC [2017] EWHC 1705 (reported in Tax Journal 14 July 2017) is the latest in a line of cases in which the exercise of HMRC’s discretionary power to issue APNs has been challenged in the High Court. HMRC had agreed to postpone the payment of a disputed tax liability pending the resolution of the substantive dispute before the FTT but then reversed the arrangements and issued APNs. The issue for judicial review was whether it was an abuse of power for HMRC to resile (abandon its position) from its express promise not to enforce payment pending the resolution of...
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Jeanette Zaman and Zoe Andrews (Slaughter and May) review recent developments affecting the City.
Judicial review
Several recent judicial review cases demonstrate the uphill battle taxpayers face in seeking to challenge actions taken by HMRC on public law grounds.
Dickinson: accelerated payment notices (APNs)
J Dickinson v HMRC [2017] EWHC 1705 (reported in Tax Journal 14 July 2017) is the latest in a line of cases in which the exercise of HMRC’s discretionary power to issue APNs has been challenged in the High Court. HMRC had agreed to postpone the payment of a disputed tax liability pending the resolution of the substantive dispute before the FTT but then reversed the arrangements and issued APNs. The issue for judicial review was whether it was an abuse of power for HMRC to resile (abandon its position) from its express promise not to enforce payment pending the resolution of...
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:
