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E Dunne and V Gray v CRC, Queen’s Bench Division
HMRC issued partner payment notices – the equivalent of accelerated payment notices – under FA 2014 sch 32 for more than £330 000.
They were sent to the claimants in relation to an arrangement that was notified to the Revenue under the disclosure of tax avoidance schemes regime.
The claimants applied for judicial review challenging the notices and sought an injunction to prevent the taxman from enforcing the notices and from issuing penalty assessments until the review was determined.
They would have either had to pay the tax or face fines if the judicial review failed without an injunction in place.
HMRC opposed the application but said they would consider interim relief in that they...
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