R (on the application of Graham and others) v Revenue and Customs Commissioners

Tax – Avoidance. The Administrative Court dismissed the claimants' application for judicial review of the defendant Revenue and Customs Commissioners' issue of accelerated payment notices and partner payment notices. Four partnerships had been notifiable arrangements, pursuant to s 308(3) of the Finance Act 2004, although the relevant proposal had been made before the Tax Avoidance Schemes (Prescribed Descriptions of Arrangements) Regulations 2006, SI 2006/1543, had come into force.

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