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Pandora’s box
Key points
- The effect of the Court of Appeal decision in Hoey is such that HMRC can effectively formulate its own guidance – governing an incredibly broad power (to disapply the entirety of the PAYE code) that operates without temporal limitation.
- A freedom of information request brought to light further details of HMRC’s otherwise unpublished Avoidance Handling Manual.
- Taxpayers have no way of knowing if there is more guidance that has not yet been revealed. Or if it will be changed.
- Mr Hoey’s legal team submitted their application for permission to appeal to the Supreme Court on 9 June 2022.
In my article titled ‘Friday the 13th’ (Taxation 2 June 2022 page 8) I looked at the recent Court of Appeal decision in Hoey and others v CRC [2022] EWCA Civ 656 and raised a number of issues that I felt should be of concern to...
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