JUDICIAL-REVIEW

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

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

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.

Zoe Andrews

Jeanette Zaman

Jeanette Zaman and Zoe Andrews (Slaughter and May) review recent developments affecting the City.

Adam Craggs

Michelle Sloane

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

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

Patrick Cannon

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.

Cathya Djanogly

Claim for judicial review of an advance payment notice rejected

Mark Whitehouse

Peter Halford

Mark Whitehouse and Peter Halford (PwC Legal) consider Whipple J’s judgment in R (oao Hely-Hutchinson) v HMRC. This important decision is likely to significantly curtail HMRC’s power to depart from published guidance.

Gideon Sanitt

Gideon Sanitt (Macfarlanes) considers the rise in judicial review applications against HMRC, and the difficulty for taxpayers in holding HMRC to account.

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