To much media attention, UK Uncut has lost its application for judicial review of HMRC’s settlement with Goldman Sachs. However, UK Uncut has shown that such a review is possible, and the judgment shows what more would need to be established if such a review were to succeed. The hurdle for a judicial review of this type remains very high, and even a successful judicial review would not necessarily result in a settlement being quashed. Taxpayers should learn from the case, and make efforts to ‘JR-proof’ future settlements with HMRC.
