- Court of Appeal on FNs and APNs—exhaust representations procedure before making judicial review claim (R (oao M Sport) v HMRC)
- What are the practical implications of this case?
- What was the background?
- What did the Court of Appeal decide?
- Case details
Tax analysis: In R (oao M Sport) v HMRC  EWCA Civ 561, the Court of Appeal dismissed the taxpayer's appeal, holding that it was not entitled to recover its costs in commencing judicial review (JR) proceedings because they had been made prematurely, ie without waiting for HMRC's response to the taxpayer's representations about the follower notice (FN) and the accelerated payment notice (APN). The JR time limit would not have started to run until this response had been received.
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