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Tax appeals and judicial review: Reed Employment Plc

Running a tax appeal together with a judicial review application can pose strategic and practical problems. If the tax appeal is heard before the judicial review and the taxpayer were to lose this may effectively establish that the taxpayer could not have a legitimate expectation that HMRC would afford the taxpayer the treatment he considered he had been promised. If the substantive issue is decided first against the taxpayer this could therefore mean that the judicial review would fail too. Further in complex cases it can be difficult to separate the evidence out into that relevant to the judicial review and that relevant to the tax appeal. The matters may be interconnected and having separate hearings could lead to duplication and unnecessary expense. In Reed Employment Plc v HMRC [2010] UKFTT 596 (TC) the taxpayer sought an innovative solution to these conundrums...

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