The Supreme Court has confirmed that HMRC is only entitled to issue follower notices where it is of the opinion that there is no scope for a reasonable person to disagree that an earlier judicial ruling determines the taxpayer’s case. The judgment confirms that HMRC’s application of the legislation since its introduction in 2014 has been fundamentally flawed. It also gives comfort to taxpayers that the higher courts are willing to restrict HMRC’s anti-avoidance powers, especially where those powers intrude upon taxpayers’ access to justice.
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The Supreme Court has confirmed that HMRC is only entitled to issue follower notices where it is of the opinion that there is no scope for a reasonable person to disagree that an earlier judicial ruling determines the taxpayer’s case. The judgment confirms that HMRC’s application of the legislation since its introduction in 2014 has been fundamentally flawed. It also gives comfort to taxpayers that the higher courts are willing to restrict HMRC’s anti-avoidance powers, especially where those powers intrude upon taxpayers’ access to justice.
If you are not a subscriber, subscribe now to read this content.
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