R (on the application of Archer and another) v Revenue and Customs Commissioners

Costs – Judicial review. The right to make representations, pursuant to s 222 of the Finance Act 2014, was an appropriate alternative remedy which the taxpayer could and should exhaust before bringing judicial review proceedings. Accordingly, the Administrative Court, in dismissing the claimant taxpayers' appeal, held that the master had correctly concluded that there should be no order for costs upon the basis that the claim for judicial review was premature because the taxpayers' had failed to exploit the statutory right to make representations to the defendant Revenue and Customs Commissioners which could and almost certainly would have led to resolution of the dispute.

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