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Cases: Autumn 2020 review


1. Informal investigation not ultra vires Court of Appeal rules


In JJ Management LLP and others v HMRC [2020] EWCA Civ 784 (reported in Tax Journal 19 July) the Court of Appeal found that HMRC is entitled to conduct informal investigations into a taxpayer’s affairs outside the normal statutory time limits where compliance with requests for information is entirely voluntary; and that a judicial review into the conduct of such an informal investigation is likely to be entertained and successful only in wholly exceptional circumstances.

Why it matters: Writing in Tax Journal (24 July) Kate Ison and Jessica Hocking (Bryan Cave Leighton Paisner) observed: ‘This decision will be welcomed by HMRC: its effect is to strengthen the already extensive powers available to HMRC to enquire into a taxpayer’s position with little checks or balances. Conversely it is likely to cause concerns for many...

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