Challenge to accelerated payment notices relating to corporation tax allegedly due


Re: R (Vital Nut Co Ltd & Anor) v Revenue & Customs Commissioners [2016] EWHC 1797 (Admin)

The claimant companies set up employment financed retirement benefit schemes, and were advised that this would enable them to claim relief from corporation tax for employer contributions. Revenue served accelerated payment notices (APNs), requiring them to pay revenue equal to the unpaid corporation tax. They sought judicial review, arguing that the issuing of the APNs was ultra vires the Finance Act 2014 s 219, 220 and 223.

Jessica Simor QC was involved in this case.