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04 August 2015
Rowe, Worrall and others v CIR [2015] EWHC 2293
Andrew Hubbard considers the implications of the lost challenge to accelerated payment notices.
The important decision in the judicial review challenge to accelerated payment notices (Rowe Worrall and others v CIR [2015] EWHC 2293) has been issued.
About 150 investors in various Ingenious film partnerships challenged HMRC’s issue of partner payment notices (PPNs) requiring up-front payments of tax pending the resolution of enquiries into the arrangements. The mechanism for PPNs is slightly different from that for accelerated payment notices (APNs) but as far as I can see the principles in this case will also apply to the latter.
There is no right of appeal against a PPN or APN so they can be challenged by judicial review only. Various grounds for review were raised during...
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