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Dickinson and others v CRC, Court of Appeal, 18 December 2018
The taxpayers were in dispute with HMRC over contractor loan agreements that had been notified under the disclosure of tax avoidance schemes (DOTAS) regime. The Revenue said the loans were taxable income and in early 2014 raised discovery assessments. The taxpayers appealed and applied to postpone the tax charged. HMRC agreed the postponement application.
In March 2015 HMRC issued accelerated payment notices (APNs) requiring payment of the postponed tax. The taxpayers sought judicial review claiming the issue of the APNs was an abuse of power in effect reversing the effect of the postponement agreements. The High Court found in favour of HMRC and the claimants...
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