R (oao Bampton Group Ltd) v King (HMRC) (and related applications)

In R (oao Bampton Group Ltd) v King (HMRC) (and related applications) (CA – 21 December) several associated companies whose accounting periods were not identical submitted claims to group relief in excessive amounts because the relevant profits and losses had been time-apportioned incorrectly. The companies’ accountants subsequently made a late claim for some of the relief to be set against the profits of another company in the group. HMRC rejected the claim on the basis that it had been made outside the statutory time limit. The companies applied for judicial review contending that HMRC should have alerted them to the mistakes in the original claims more promptly and that the rejection of the late claim was irrational. The QB rejected these contentions and dismissed the applications. Blair J held that ‘in a commercial setting such as this the responsibility for formulating a claim...