Monthly Archives: March 2017

Mansworth v Jelley revisited in the Court of Appeal

Listed for hearing before the Court of Appeal today is the case of R (Hely Hutchinson) v HMRC. The case revolves around the controversial Mansworth v Jelley claims. The taxpayer Ralph Hely-Hutchinson was successful before the High Court in this judicial review (which … Continue reading

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Another ‘Accelerated Payment’ case, another loss for the taxpayers

Accelerated Payment Notices (‘APNs’) and Partner Payment Notices (‘PPNs’) have since 2014 been clogging up the Administrative Court. A rough estimate suggests that up to 87 cases have been petitioned for review.[1] In fact, there are currently 4,116 applicants or … Continue reading

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The Good Law Project’s Uber case

Jolyon Maugham QC recently started the ‘Good Law Project’, which seeks to “use strategic legal cases both to change how the law works and to drive demand for further law change”. The first such case seeks to challenge the business … Continue reading

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Gulliver v HMRC and the appeal/review distinction

Many countries operate a system of ‘rulings’ whereby taxpayers can approach the revenue authority of that country and ask for a determination in relation to particular elements of their tax affairs or in relation to specific transactions. Some countries have … Continue reading

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Case note in the British Tax Review

In a piece published in the March issue of the British Tax Review (available on Westlaw and here), I look at the recent case of Ingenious Media. This is a case I have blogged about on numerous occasions (here, here, here and here). … Continue reading

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