{"availability":"open","schema":"taxsorted.uk.case-commons/1","scope":"complete-reviewed-ledger","sourceUseBoundary":"Official self-description supports only the claim named in supports. Read limitations and the source itself before reuse.","sources":[{"id":"uksc-haworth-2021-case","kind":"official-court-case-page","limitations":["The page summary is not a substitute for the judgment","The case did not determine the underlying capital-gains-tax appeal"],"publisher":"UK Supreme Court","retrievedAt":"2026-07-24","status":"decided","supports":["Parties, issues, facts, dates and citation","The Court of Appeal quashed the follower and accelerated-payment notices"],"title":"R (Haworth) v HMRC — case page","url":"https://supremecourt.uk/cases/uksc-2019-0124"},{"id":"uksc-haworth-2021-judgment","kind":"court-judgment","limitations":["The amount was an up-front demand on disputed tax, not damages or an award","Mr Haworth had not made the accelerated payment"],"publisher":"UK Supreme Court","retrievedAt":"2026-07-24","status":"decided","supports":["The statutory follower-notice test and the Court's reasons","The £8,786,288.40 accelerated-payment notice","The then-applicable broad 50% penalty, reducible for cooperation but not below 10%","No penalty was imposed within the statutory time limit"],"title":"R (Haworth) v HMRC [2021] UKSC 25 — judgment","url":"https://supremecourt.uk/uploads/uksc_2019_0124_judgment_90ad362b5f.pdf"},{"id":"uksc-haworth-2021-press-summary","kind":"official-court-summary","limitations":["The summary says it is not part of the reasons; the judgment is authoritative"],"publisher":"UK Supreme Court","retrievedAt":"2026-07-24","status":"decided","supports":["The Supreme Court unanimously dismissed HMRC's appeal","HMRC's 'likely' view did not meet the statutory threshold","HMRC had overstated the earlier Smallwood ruling","The penalty pressure engaged the constitutional right of access to justice"],"title":"R (Haworth) v HMRC [2021] UKSC 25 — press summary","url":"https://supremecourt.uk/uploads/uksc_2019_0124_press_summary_a2a4362049.pdf"},{"id":"ukut-haworth-2024","kind":"official-tribunal-decision-page","limitations":["This is a later, separate appeal about the underlying tax liability rather than the validity of the 2016 notices"],"publisher":"HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)","retrievedAt":"2026-07-24","status":"decided","supports":["The separate substantive tax appeal and its 2024 Upper Tribunal stage","The Upper Tribunal dismissed the taxpayers' appeals"],"title":"Haworth and others v HMRC [2024] UKUT 00058 (TCC)","url":"https://www.gov.uk/tax-and-chancery-tribunal-decisions/geoffrey-richard-haworth-ian-francis-lenagan-sg-kleinwort-hambros-trust-company-uk-limited-v-the-commissioners-for-his-majestys-revenue-and-customs-2024-ukut-00058-tcc"},{"id":"uksc-haworth-2025-permission","kind":"official-court-case-page","limitations":["Refusal of permission is not a fresh merits judgment on the 2021 judicial-review issues"],"publisher":"UK Supreme Court","retrievedAt":"2026-07-24","status":"permission-refused","supports":["The First-tier Tribunal, Upper Tribunal and Court of Appeal rejected the underlying tax appeal","The Supreme Court refused permission on 30 October 2025 because the application did not raise an arguable point of law"],"title":"Haworth and others v HMRC — permission to appeal refused","url":"https://supremecourt.uk/cases/uksc-2025-0152"},{"id":"cpr-part-54","kind":"official-court-procedure","limitations":["This release maps England and Wales procedure only","Field-specific statutes and rules can change the route and deadline"],"publisher":"Ministry of Justice","retrievedAt":"2026-07-24","status":"current","supports":["Judicial review concerns lawfulness of an enactment or a decision, action or failure in a public function","Permission is required","The general prompt and three-month filing limit and the existence of shorter limits","Quashing, mandatory and prohibiting orders, declarations and injunctions","Damages, restitution or recovery of a sum may be joined but not sought alone under the judicial-review procedure"],"title":"Civil Procedure Rules Part 54 — Judicial Review and Statutory Review","url":"https://www.justice.gov.uk/courts/procedure-rules/civil/rules/part54"},{"id":"jr-pre-action-protocol","kind":"official-court-procedure","limitations":["Urgent cases and specialist proceedings can require a different approach","The protocol strongly advises appropriate legal advice"],"publisher":"Ministry of Justice","retrievedAt":"2026-07-24","status":"current","supports":["The protocol's England and Wales scope and aims","The need to identify issues, exchange information and consider settlement","Judicial review normally should not be used where an adequate alternative remedy exists","Protocol steps do not stop the judicial-review clock"],"title":"Pre-Action Protocol for Judicial Review","url":"https://www.justice.gov.uk/courts/procedure-rules/civil/protocol/prot_jrv"},{"id":"sra-solicitors-register","kind":"official-professional-register","limitations":["Register status does not prove competence, availability or 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Register","url":"https://www.barstandardsboard.org.uk/for-the-public/search-a-barristers-record/the-barristers-register.html"},{"id":"senior-courts-act-section-31","kind":"primary-legislation","limitations":["Current procedural rules, later amendments and the facts still control"],"publisher":"The National Archives","retrievedAt":"2026-07-24","status":"current","supports":["The High Court's judicial-review remedies and sufficient-interest requirement","The conditions for joining a damages claim to judicial review"],"title":"Senior Courts Act 1981, section 31","url":"https://www.legislation.gov.uk/ukpga/1981/54/section/31"},{"id":"human-rights-act-section-7","kind":"primary-legislation","limitations":["The court can allow a longer period where equitable, and another applicable procedure can impose a stricter time limit"],"publisher":"The National Archives","retrievedAt":"2026-07-24","status":"current","supports":["Victim status and the general one-year period for proceedings against a public authority"],"title":"Human Rights Act 1998, section 7","url":"https://www.legislation.gov.uk/ukpga/1998/42/section/7"},{"id":"human-rights-act-section-8","kind":"primary-legislation","limitations":["Damages are not automatic and require the court to be satisfied they are necessary for just satisfaction"],"publisher":"The National Archives","retrievedAt":"2026-07-24","status":"current","supports":["The court's just-and-appropriate relief and discretionary damages test"],"title":"Human Rights Act 1998, section 8","url":"https://www.legislation.gov.uk/ukpga/1998/42/section/8"},{"id":"hmrc-tax-appeal-guidance","kind":"official-tax-guidance","limitations":["The exact decision notice, tax and statute determine whether and how an appeal exists"],"publisher":"HM Revenue and Customs","retrievedAt":"2026-07-24","status":"current","supports":["The ordinary HMRC review and appeal route and common 30-day response period"],"title":"Disagree with a tax decision","url":"https://www.gov.uk/tax-appeals/decision"},{"id":"hmcts-tax-tribunal-guidance","kind":"official-tribunal-guidance","limitations":["It is general procedural guidance, not a decision that a particular appeal is valid or in time"],"publisher":"HM Courts & Tribunals Service","retrievedAt":"2026-07-24","status":"current","supports":["How and when a tax appeal can move to the First-tier Tribunal"],"title":"Appeal to the tax tribunal","url":"https://www.gov.uk/tax-tribunal/appeal-to-tribunal"},{"id":"hmrc-complaint-guidance","kind":"official-tax-guidance","limitations":["A complaint is distinct from challenging a tax decision and does not itself change the appeal clock"],"publisher":"HM Revenue and Customs","retrievedAt":"2026-07-24","status":"current","supports":["HMRC's published service-complaint route"],"title":"Complain about HMRC","url":"https://www.gov.uk/complain-about-hmrc"},{"id":"cpr-part-44","kind":"official-court-procedure","limitations":["The court can make a different order after considering conduct, partial success and other circumstances"],"publisher":"Ministry of Justice","retrievedAt":"2026-07-24","status":"current","supports":["The court's discretion on costs and the general rule that the unsuccessful party pays the successful party's costs"],"title":"Civil Procedure Rules Part 44 — General rules about costs","url":"https://www.justice.gov.uk/courts/procedure-rules/civil/rules/part-44-general-rules-about-costs"},{"id":"sra-no-win-no-fee","kind":"official-professional-guidance","limitations":["The actual retainer and funding documents control the client's obligations"],"publisher":"Solicitors Regulation Authority","retrievedAt":"2026-07-24","status":"current","supports":["Consumer cautions and cost questions for conditional-fee arrangements"],"title":"No win, no fee agreements","url":"https://www.sra.org.uk/consumers/choosing/no-win-no-fee/"},{"id":"fca-claims-management-regulation","kind":"official-regulator-guidance","limitations":["Whether a particular platform activity is regulated needs fact-specific perimeter advice"],"publisher":"Financial Conduct Authority","retrievedAt":"2026-07-24","status":"current","supports":["The FCA regulates claims-management companies in specified sectors and activities can require authorisation"],"title":"Claims management regulation","url":"https://www.fca.org.uk/firms/claims-management-regulation"},{"id":"sra-unsolicited-approaches","kind":"official-professional-guidance","limitations":["The exact rule and permitted communication depend on the professional and circumstances"],"publisher":"Solicitors Regulation Authority","retrievedAt":"2026-07-24","status":"current","supports":["Professional duties affecting unsolicited approaches and clear, accurate publicity"],"title":"Unsolicited approaches and advertising","url":"https://www.sra.org.uk/solicitors/guidance/unsolicited-approaches-advertising/"},{"id":"legal-services-act-section-12","kind":"primary-legislation","limitations":["Entitlement, exemptions and offence provisions require the rest of the Act and current regulatory rules"],"publisher":"The National Archives","retrievedAt":"2026-07-24","status":"current","supports":["The statutory categories of reserved legal activity"],"title":"Legal Services Act 2007, section 12","url":"https://www.legislation.gov.uk/ukpga/2007/29/section/12"},{"id":"defamation-act-2013","kind":"primary-legislation","limitations":["A public-interest label or website-operator status is not automatic immunity"],"publisher":"The National Archives","retrievedAt":"2026-07-24","status":"current","supports":["The statutory framework for defamation claims and defences in England and Wales"],"title":"Defamation Act 2013","url":"https://www.legislation.gov.uk/ukpga/2013/26"},{"id":"contempt-of-court-act-1981","kind":"primary-legislation","limitations":["Reporting restrictions and common-law contempt also require case-specific review"],"publisher":"The National Archives","retrievedAt":"2026-07-24","status":"current","supports":["The statutory contempt framework relevant to publications about active proceedings"],"title":"Contempt of Court Act 1981","url":"https://www.legislation.gov.uk/ukpga/1981/49"},{"id":"ico-dpia-guidance","kind":"official-data-protection-guidance","limitations":["A DPIA is one part of lawful processing, not permission to publish"],"publisher":"Information Commissioner's Office","retrievedAt":"2026-07-24","status":"current","supports":["When high-risk personal-data processing requires a data-protection impact assessment"],"title":"When do we need to do a DPIA?","url":"https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/accountability-and-governance/data-protection-impact-assessments-dpias/when-do-we-need-to-do-a-dpia/"}],"stoppedCaseCount":0,"version":"2026-07-24.1"}