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Resolving the conflict
In 2005, the current Chancellor of the Exchequer said: ‘A taxpayer is entitled to know with certainty… what he may or ma...
Untangling the Gordion Knot
The decision in The Queen on the Application of Mr De Silva and Anr v The Commissioners for Her Majesty’s Revenue and Cu...
Four legs good, two legs bad
The first judicial review decision on accelerated payment notices (APNs) was in the case of Rowe and Others v RCC [2015]...
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Let battle commence
Most commentary on the practicalities of accelerated payment notices (APNs) dates to the period of a ‘phony war’, when t...