JUDICIAL-REVIEW

The Government might have consulted but it hasn’t listened.

Principled positions often adopted by HMRC can have the practical effect of avoiding or otherwise delaying judicial scrutiny of their decision-making process, write Richard Doran and John Hayton (Joseph Hage Aaronson & Bremen).

Daniel Williams

Michelle Sloane

A recent High Court decision provides valuable guidance for taxpayers seeking to challenge enforcement action taken by HMRC’s Debt Management team, write Michelle Sloane and Daniel Williams (RPC).

Adam Craggs

Liam McKay

Adam Craggs and Liam McKay (RPC) review lessons from several important procedural decisions and a successful challenge to HMRC’s approach to subject access requests.

Bridget Winters

Calum Young

In an adversarial system, when can the tribunal take the initiative and reach decisions on arguments not made by counsel? Bridget Winters and Calum Young (Taylor Wessing) investigate.

HMRC’s revised view of UK–Spain treaty residence not amenable to judicial review

Judicial review determining tax residency: K (oao R Houldsworth) v HMRC [2025] EWHC 2848 (Admin) (4 November) revisits an issue which many people might have thought had gone away: the extent to which the (former) IR20 booklet can be relied on when...

Judicial review concerning legitimate expectation over domicile status

Disguised remuneration schemes, end users and judicial review: It is now accepted that most, if not all, disguised remuneration schemes involving the making of loans to employees via an employee benefit trust do not work and that the arrangements...

Upper Tribunal decides that HMRC lawfully refused late claim under SP 5/01

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