11 November 2024
R (Payeworx Ltd) v HMRC [2024] EWHC 2842 (Admin)
The Administrative Court has refused permission for a claim for judicial review to be brought challenging HMRC’s decision to publish details under s86 Finance Act 2022 in respect of ‘relevant arrangements’, namely arrangements that might enable any person to obtain a tax advantage and the advantage is one of the main benefits that might be expected from the arrangements. The Court confirmed that the requirement for HMRC to suspect that arrangements are relevant arrangements is a low bar and it was not irrational in the present case for HMRC to form their view. In addition, even if Article 1 of the First Protocol was engaged, there was no disproportionate interference with the Claimant’s rights.
Ben Elliott acted for HMRC.
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