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Rokos, R (On the Application Of) v Revenue and Customs [2026] EWHC 733 (Admin) (26 March 2026)
The High Court dismissed Christopher Rokos’s judicial review challenge to HMRC’s amendments, holding that enquiry notices for two film partnerships were validly given through authorised agents.
Permission to bring a late appeal was granted because, for the amendments to the partnership returns, the appellant had a good reason for the delay: HMRC’s correspondence reasonably led him to believe he had no right of appeal. For the discovery assessment and penalty, although there was no good reason for the delay, the incremental prejudice to HMRC was small and it would be unjust to refuse permission for 2019-20 when the same factual dispute would be litigated for earlier years. The three-stage Martland test was applied, following Medpro and Pawar, and the balancing exercise favored granti…
Source excerpt
Gala Film Partners LLP did not carry on a trade in the 2003/04 tax year, or, if it did, not with a view to profit. The arrangements were designed to generate a self-funded loss for tax relief, not to conduct genuine commercial trading activity. The expenditure was not incurred wholly and exclusively for the purposes of any trade, and the accounting treatment did not comply with GAAP. Loss relief and interest relief were not available to the members.
Source excerpt
There are reasonable grounds for not directing HMRC to issue a closure notice for the s 9A enquiry into Mr Stockler’s 2017-18 return, as the quantum of partnership losses is still under investigation and partnership enquiries have not yet reached a stage where HMRC can make an informed judgment. The ongoing partnership enquiries are central to the individual enquiry and have not been unreasonably delayed.
Source excerpt
Judicial review over Partner Payment Notices was dismissed. The court held Schedule 32 applies to LLPs and that HMRC had valid notices of enquiry.
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