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HMRC raised assessments on the taxpayer under TMA 1970 s 29.
They also made a direction under reg 72(5) of the Income Tax (PAYE) Regulations 2003 SI 2682/03 in respect of income tax not deducted by an employer. The taxpayer sought to appeal the assessments to the First-tier Tribunal.
An assessment under s 29 gave rise to a statutory debt enforceable under s 68 in the High Court. On the same day as they issued the assessments HMRC claimed in respect of the tax and also applied for a without notice worldwide freezing injunction against the taxpayer.
The taxpayer argued that the court did not have jurisdiction to grant a freezing injunction as before such an injunction could be made an...
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