In its recent decision in Hoey and others v CRC [2022] EWCA Civ 656 the Court of Appeal commented (at para 132): ‘In any event we do not regard this result as … impeding access to justice … The attractions of the First-tier Tribunal as a “one stop shop” for all issues concerning the amount taxpayers should be required to pay to HMRC cannot alter the meaning and effect of a legislative scheme that … requires certain issues to be litigated in the tax Tribunal others to be litigated by way of judicial review in the High Court … and disputes about the amount to be collected by HMRC dealt with as a matter of enforcement in the civil Courts (the County Court or High Court)’.
An accidental scheme
The emphasis on the word ‘scheme’ is mine not the Court of Appeal’s. To my...
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