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Is there a lot of phooey over Hoey?
Key points
- There has been much debate over the Court of Appeal decision in Hoey and specifically concerns about the lack of review or appeal when HMRC exercised its discretionary power in ITEPA 2003 s 684(7A) retroactively.
- We must look at the interactions between the PAYE system and the liability to tax and tax assessment and collection.
- Is the use of discretionary powers in Hoey calamitous? It is probably not and the evidence obtained under the freedom of information powers also points to the same conclusion.
- HMRC seems to have used its discretionary power under ITEPA 2003 s 684(7A) in a particularly specific and targeted manner.
Readers will have seen recent articles in Taxation concerning the Court of Appeal decision in Hoey and others v CRC [2022] ECWA Civ 656 (see ‘Friday the 13th’ by Matt Hall 2 June 2022 page 8 and ‘Does...
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