Queen’s Bench Division
Regina (Archer) v Revenue and Customs Commissioners
[2018] EWHC 695 (Admin)
2018 March 6; 28
Green J
RevenueTax avoidanceAccelerated payment noticeRevenue serving accelerated payment notice on claimantClaimant commencing judicial review proceedings contending revenue should withdraw noticeJudicial review proceedings compromised in claimant’s favour Master refusing claimant’s application for costs finding claim premature pending exercise of claimant’s statutory right to make representations to revenue regarding payment noticeWhether statutory right to make representations being adequate alternative remedy to judicial review proceedingsWhether master erring Finance Act 2014 (c 26), ss 219, 222

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