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JUDICIAL-REVIEW


Card image Adam Craggs, Robert Waterson, Constantine Christofi
Adam Craggs, Robert Waterson and Constantine Christofi (RPC) examine the High Court decision that refused permission to bring a judicial review claim against HMRC.
A 20 questions guide, by Adam Craggs and Constantine Christofi (RPC).
Barrister Michael Thomas (Pump Court Tax Chambers) believes there is a disturbing trend in our tax jurisprudence: an increasing number of important decisions made by HMRC are only capable of being challenged on a judicial review basis.

Adam Craggs and Constantine Christofi (RPC) consider the recent spate of IR35 cases that have been considered by the First-tier Tribunal, HMRC's increasing use of 'jeopardy amendments' and the increasing number of judicial review challenges being brought against HMRC.  

Ray McCann (CIOT) raises concerns for taxpayers’ rights as HMRC’s powers appear only to be challenged through expensive and uncertain judicial review.
 
Richard Jeens (Slaughter and May) reviews a busy year for tax disputes, both in terms of the scale and number of DPT and transfer pricing enquiries and a number of significant court decisions.
 
Jeanette Zaman and Zoe Andrews (Slaughter and May) review recent developments affecting the City.
 
Adam Craggs and Michelle Sloane (RPC) review the recent High Court judgment in Archer which dismissed a judicial review application on grounds the taxpayer should have appealed to the First-tier Tribunal.
 

Andrew Scott (Pinsent Masons) considers the various linguistic concepts in determining taxpayer conduct towards paying tax.

Taxpayers should question their legal advisers carefully about bringing future challenges to the accelerated payment notices regime if they are not to throw good money after bad. Patrick Cannon (15 Old Square) reviews the four reported judicial review challenges to APNs of note.
 
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