Another wheel

Peter Vaines in Then the wheels fell off… suggested that ‘HMRC have a wider responsibility to the community which was perhaps well expressed in the recent case of Hok Limited TC1286’.

It isn’t only Peter who thinks this way. Lord Justice Simon Brown in R v CIR ex parte Unilever Plc [1996] STC 681 said:

‘Public authorities in general and taxing authorities in particular are required to act in a high-principled way on occasions being subject to a stricter duty of fairness than would apply as between private citizens. This approach is exemplified in cases such as R v Tower Hamlets LBC ex parte Chetnik Developments Ltd [1988] AC 858 and Woolwich EBS v CIR [1993] AC 70 and reflected in Lord Mustill’s reference in Matrix-Securities to...