Dickinson & Ors, R (on the application of) v HM Revenue & Customs

The application to re-amend was refused because there was no sufficient explanation for the lateness of the new ground, and no evidence of realistic prospects of success on the merits.

Source-derived case information.

Parties: Claimant: Dickinson & Ors; Defendant: Commissioners for HM Revenue & Customs
Jurisdiction: England and Wales
Judgment Date: 23 February 2017
Procedural Posture: Judicial Review / Ruling on Application to Re Amend Statement of Facts and Grounds
Outcome: Application to re-amend refused; costs order in favour of HMRC subject to detailed assessment.
Legal Topics: Accelerated Payment Notices, Judicial Review Procedure, Legitimate Expectation, Tax Avoidance Schemes

Tax Law Administrative Law Accelerated Payment Notices Judicial Review Procedure Legitimate Expectation Tax Avoidance Schemes

Source-derived case record

Summary, issues, holding and outcome

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Full judgment text Downloadable case file Legal principles 2 Authorities cited 1 Party arguments 2

Parties

Dickinson & Ors

Claimant

Commissioners for HM Revenue & Customs

Defendant

Procedural Posture

Judicial Review / Ruling on Application to Re Amend Statement of Facts and Grounds

Legal Issues

1 Whether claimants should be permitted to re-amend their statement of facts and grounds to introduce a new challenge to the lawfulness of APNs based on notifiability of the scheme
2 Whether there is sufficient explanation for the lateness of the application
3 Whether the new ground has realistic prospects of success

Ratio Decidendi

The application to re-amend was refused because there was no sufficient explanation for the lateness of the new ground, and no evidence of realistic prospects of success on the merits.

Court Disposition

Application to re-amend refused; costs order in favour of HMRC subject to detailed assessment.

Orders

Application to re-amend statement of facts and grounds refused.
HMRC awarded costs of the application, subject to detailed assessment at conclusion of proceedings.

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