You must check the date from which these rules apply for the tax or duty you are dealing with. See CH81011 for full details.

The legislation at Paragraph 17 (6) in Schedule 24 says that a ‘flawed’ decision made by HMRC means that it is flawed when considered in the light of the principles applicable to proceedings for judicial review.

Judicial review allows individuals, businesses and other groups to challenge the lawfulness of decisions made by

ministers

government departments

local authorities, and

other public bodies.

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