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Strong stuff
KEY POINTS
- In the Jimenez case the first party notice under FA 2008 Sch 36 para 1 was quashed by the High Court.
- Lack of transparency and conduct of ex parte hearings.
- In essence HMRC’s case was that there is no international or jurisdictional limit to Sch 36.
- Practitioners should now expect and request a full record of an application hearing.
On 20 October 2017 the High Court released its judicial review decision in R (oao) Tony Michael Jimenez v The First-tier Tribunal (Tax Chamber) & CRC [2017] EWHC 2585 (Admin). The grant of permission for the review was previously reported in ‘Imposing territorial limitations’ (Taxation 26 January 2017)).
The decision of Charles J may make uncomfortable reading for HMRC in several areas. Not only did the High Court quash...
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