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R (on the application of) J Dickinson and others v HMRC

In R (on the application of) J Dickinson and others v HMRC [2017] EWHC 1705 (7 July 2017) the High Court dismissed a claim for judicial review of the decision to issue advance payment notices (APNs) under FA 2014 chap 3 in circumstances where an agreement to postpone the tax had been reached (TMA 1970 s 55).

The underlying disputes concerned loans paid to the claimants which HMRC contended were taxable as income and the validity of discovery assessments relating to those loans. HMRC had issued APNs after agreeing to postpone the payment of the disputed tax pending the resolution of the dispute by the FTT. The issue was whether the issue of the APNs in such circumstances had been an abuse of power based on a breach of a legitimate expectation.

The High Court listed a number of principles established by case law noting in...

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