In R (on application of M Sport) v HMRC [2021] EWCA Civ 561 (16 April 2021) the Court of Appeal dismissed the taxpayer’s appeal holding that it was not entitled to recover its costs in commencing judicial review (JR) proceedings because they had been made prematurely i.e. without waiting for HMRC’s response to the taxpayer’s representations about the follower notice (FN) and the accelerated payment notice (APN). The JR time limit would not have started to run until this response had been received.
HMRC issued an FN and an APN to the appellant company M Sport. The appellant made written representations to HMRC in respect of the FN and the APN. One of the grounds was that the notices had not been issued within the permitted time limits.
In the appellant’s view it also had grounds to challenge the issue of the FN and the APN under...
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