Other cases that caught our eye: 18 July 2025

JR challenge to APNs refused: In R (oao Adviser Business Solutions Ltd and others) v HMRC [2025] EWHC 1641 (Admin) (30 June) the HC refused permission to challenge Accelerated Payment Notices (APNs) holding that where HMRC have already formed and communicated a concluded view through PAYE determinations and NICs decisions no fresh analysis from the designated officer was required for valid APNs. The case concerned APNs issued to companies regarding tax avoidance schemes involving employee share arrangements that had been disclosed under DOTAS where HMRC had previously issued determinations and decisions which the claimants had appealed with tax collection initially postponed. The court distinguished this from cases like Vital Nut [2016] EWHC 1797 where APNs were issued during enquiries. The court also rejected the taxpayers’ argument that they had a legitimate expectation from the prior postponement agreement as TMA 1970 s 55 explicitly provided that APNs...