Appeals following unsuccessful claims for judicial review in respect of HMRC’s decision to issue accelerated payment notices and partner payment notices were dismissed.
The appellants appealed against accelerated payment notices (APNs) and partner payment notices (PPNs) served by HM Revenue and Customs (HMRC). The appeals related to a High Court order in respect of one appellant (R) dismissing an application for judicial review ([2015] EWHC 2293 (Admin)), and a similar High Court order in respect of another appellant (V) ([2016] EWHC 1797 (Admin)). R was a member of a film partnership and his case was the lead case for 81 taxpayers who participated in partnership schemes.
The appellants appealed against HMRC’s decision to issue the APNs/PPNs, on several grounds: (1) unreasonableness; (2) retrospectivity; (3) not in accordance with natural justice; (4) in relation to one of the appellants (R), that no tax
