{"case":{"citation":"[2021] UKSC 25","id":"haworth-v-hmrc-2021","packetDigest":"sha256:ef195ae9951ec5aa25a2f9ecf737ac7561d1f0b91889a7003b1ea054339aec11","packetHref":"/v1/case-commons/uk/cases/haworth-v-hmrc-2021","slug":"haworth-v-hmrc"},"derived":{"adapter":"uk.haworth-v-hmrc-2021","frameworkVersion":"2026-07-28.2","qualifiedLegalReviewAsserted":false,"taxSortedDerivedLabels":true},"expectedOutput":{"dimensions":[{"gaps":[],"id":"case-identity-and-tax-context","reading":"R (Haworth) v HMRC [2021] UKSC 25 concerns Tax administration and judicial review in England and Wales.","state":"mapped"},{"gaps":[],"id":"procedural-posture-and-route","reading":"The Supreme Court decided HMRC's appeal in judicial-review proceedings about follower and accelerated-payment notices. The underlying tax appeal remained separate.","state":"mapped"},{"gaps":["Issue 3, whether factual findings form part of the 'principles laid down or reasoning given' for Finance Act 2014 section 205(3)(b), is not separately mapped in the canonical case record.","Issue 4, whether Finance Act 2014 section 206 invalidated the notice because HMRC did not adequately explain why Smallwood determined the case, is not separately mapped in the canonical case record."],"id":"questions-and-issues","reading":"What happens when HMRC uses a penalty-backed notice that pressures a taxpayer to abandon an appeal, but has not reached the level of certainty Parliament required? The canonical packet separately maps Issues 1 and 2, but not every issue decided by the Supreme Court.","state":"partial"},{"gaps":["Complete witness, documentary and agreed-fact records are not mapped."],"id":"material-and-disputed-facts","reading":"The packet maps the trust arrangements, notice issue, stated demand and procedural outcomes. It does not reproduce the complete evidential record or every disputed fact.","state":"partial"},{"gaps":["Exact primary-legislation provision records and a complete authority table are not mapped."],"id":"governing-rules-and-authorities","reading":"The packet maps the statutory threshold through the court's findings and identifies Smallwood as the earlier authority. It does not extract a provision-by-provision primary-law ledger.","state":"partial"},{"gaps":["Map each party's grounds, submissions, concessions and requested disposition from the judgment and filed materials."],"id":"party-arguments","reading":"The packet does not give a complete, side-by-side account of each party's pleaded arguments and concessions.","state":"not-mapped"},{"gaps":["A full burden-and-standard map and the complete contemporaneous decision record are not included."],"id":"evidence-burden-and-standard","reading":"The court's reasons expose HMRC's recorded level of confidence—likely rather than the statutory 'would' threshold—but the packet does not map every burden, standard and evidential item.","state":"partial"},{"gaps":["The Senior Courts Act 1981 section 31(2A) materiality and relief analysis attached to the Smallwood misdirection is not separately mapped."],"id":"decisive-reasoning","reading":"The packet maps two independently sufficient issue branches: the statutory threshold was not met, and HMRC overstated what the earlier ruling established. The second branch's separate relief step is not mapped.","state":"partial"},{"gaps":["Every rejected or alternative argument is not mapped.","The canonical record does not separately map the court's treatment of Issues 3 and 4."],"id":"supporting-and-rejected-reasoning","reading":"The access-to-justice effect supports a restrictive reading of the power. The packet also records boundaries, but not a complete inventory of every rejected submission.","state":"partial"},{"gaps":[],"id":"holding-and-disposition","reading":"The Supreme Court unanimously dismissed HMRC's appeal, leaving both notices quashed.","state":"mapped"},{"gaps":["The complete costs, funding, interest and tax-on-recovery record is not mapped.","The Senior Courts Act 1981 section 31(2A) materiality and relief analysis is not separately mapped, so this view does not imply that every legal error produces quashing."],"id":"remedies-money-and-costs","reading":"£8.786m demand affected; no damages award identified. The notices were quashed; the packet identifies no damages award or established net recovery and does not quantify complete costs.","state":"partial"},{"gaps":["No new person's facts, decision document, current deadline or professional assessment is present."],"id":"later-history-transfer-limits-and-counterfactuals","reading":"The later merits appeal failed. Transfer to another matter requires the exact current power, notice, reasoning record, route, facts and clock; similarity alone is not enough.","state":"partial"}]},"id":"haworth-v-hmrc-2021:2026-07-28.2:map-dimensions","input":{"caseId":"haworth-v-hmrc-2021","frameworkVersion":"2026-07-28.2","packet":{"digest":"sha256:ef195ae9951ec5aa25a2f9ecf737ac7561d1f0b91889a7003b1ea054339aec11","href":"/v1/case-commons/uk/cases/haworth-v-hmrc-2021"}},"instruction":"Map the approved public case packet across all twelve framework dimensions. 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{"case":{"citation":"[2021] UKSC 25","id":"haworth-v-hmrc-2021","packetDigest":"sha256:ef195ae9951ec5aa25a2f9ecf737ac7561d1f0b91889a7003b1ea054339aec11","packetHref":"/v1/case-commons/uk/cases/haworth-v-hmrc-2021","slug":"haworth-v-hmrc"},"derived":{"adapter":"uk.haworth-v-hmrc-2021","frameworkVersion":"2026-07-28.2","qualifiedLegalReviewAsserted":false,"taxSortedDerivedLabels":true},"expectedOutput":{"decisiveReasonIds":["reason:threshold-not-met","reason:earlier-ruling-overstated"],"holding":"The Supreme Court dismissed HMRC's appeal and left the follower and accelerated-payment notices quashed. The mapped record identifies two independently sufficient issue branches: the statutory threshold was not met, and HMRC had overstated the earlier authority; the second branch's separate relief step remains explicitly unmapped.","steps":[{"decisiveness":"decisive","gaps":[],"id":"reason:threshold-not-met","issueBranch":"issue-1-statutory-threshold","proposition":"HMRC's conclusion that the earlier Smallwood ruling was likely to deny the tax advantage did not meet the statutory use of 'would'. The required opinion left no scope for a reasonable person to disagree."},{"decisiveness":"decisive","gaps":["The canonical case record does not separately map the court's Senior Courts Act 1981 section 31(2A) materiality and relief step. This proposition must not be read as saying every legal misdirection requires quashing."],"id":"reason:earlier-ruling-overstated","issueBranch":"issue-2-smallwood-and-relief","proposition":"HMRC misdirected itself by treating seven indicators from Smallwood as inevitably locating the trust's effective management in the UK."},{"decisiveness":"supporting","gaps":[],"id":"reason:access-to-justice","issueBranch":"issue-1-statutory-context","proposition":"Because the penalty risk discouraged a taxpayer from continuing an appeal, the regime interfered with access to justice and the statutory power had to be interpreted restrictively."},{"decisiveness":"boundary","gaps":["The packet does not give a single pinpoint for this cross-proceeding boundary."],"id":"boundary:underlying-tax-not-decided","issueBranch":"cross-proceeding-boundary","proposition":"Quashing the notices did not decide whether the underlying tax was due."},{"decisiveness":"boundary","gaps":["The packet maps the later disposition but not every argument or finding in the separate merits appeal."],"id":"boundary:later-merits-loss","issueBranch":"later-merits-history","proposition":"The underlying tax appeal was later dismissed through the First-tier Tribunal, Upper Tribunal and Court of Appeal; the Supreme Court refused permission to appeal."}]},"id":"haworth-v-hmrc-2021:2026-07-28.2:identify-decisive-reasons","input":{"caseId":"haworth-v-hmrc-2021","holding":"The Supreme Court dismissed HMRC's appeal and left the follower and accelerated-payment notices quashed. The mapped record identifies two independently sufficient issue branches: the statutory threshold was not met, and HMRC had overstated the earlier authority; the second branch's separate relief step remains explicitly unmapped.","packet":{"digest":"sha256:ef195ae9951ec5aa25a2f9ecf737ac7561d1f0b91889a7003b1ea054339aec11","href":"/v1/case-commons/uk/cases/haworth-v-hmrc-2021"}},"instruction":"Identify concise public reasons that were outcome-determinative within an issue or formed an independently sufficient branch. Keep supporting reasons, incomplete steps and boundaries distinct. Do not provide hidden chain-of-thought.","provenance":{"casePointers":["/counterweights/0","/counterweights/1","/findings/0","/findings/1","/findings/2","/timeline/4","/timeline/5"],"sourceIds":["uksc-haworth-2021-case","uksc-haworth-2021-judgment","uksc-haworth-2021-press-summary","uksc-haworth-2025-permission","ukut-haworth-2024"]},"safety":{"containsPrivateMatterFacts":false,"hiddenChainOfThought":false,"outcomePrediction":false,"qualifiedLegalReviewAsserted":false,"sourcePacketApproved":true,"taxSortedDerivedLabels":true},"schema":"taxsorted.uk.tax-dispute-training-example/1","split":"evaluation","taskFamily":"identify-decisive-reasons"}
{"case":{"citation":"[2021] UKSC 25","id":"haworth-v-hmrc-2021","packetDigest":"sha256:ef195ae9951ec5aa25a2f9ecf737ac7561d1f0b91889a7003b1ea054339aec11","packetHref":"/v1/case-commons/uk/cases/haworth-v-hmrc-2021","slug":"haworth-v-hmrc"},"derived":{"adapter":"uk.haworth-v-hmrc-2021","frameworkVersion":"2026-07-28.2","qualifiedLegalReviewAsserted":false,"taxSortedDerivedLabels":true},"expectedOutput":{"outcomes":{"money":{"casePointers":["/financialEffect"],"sourceIds":["cpr-part-44","sra-no-win-no-fee","uksc-haworth-2021-judgment","ukut-haworth-2024"],"status":"documented-amount-affected-not-recovery","summary":"£8.786m demand affected; no damages award identified. The reviewed official sources identify no damages award in these proceedings. The sources identify no damages award, Mr Haworth had not paid the accelerated amount, the underlying tax appeal later failed, and this packet has no complete costs, interest, funding or tax-on-recovery record."},"procedural":{"casePointers":["/timeline/3","/remedies/0","/remedies/1"],"sourceIds":["uksc-haworth-2021-case","uksc-haworth-2021-judgment","uksc-haworth-2021-press-summary","ukut-haworth-2024"],"status":"notices-quashed","summary":"HMRC's appeal was dismissed and the follower and accelerated-payment notices remained quashed."},"underlyingMerits":{"casePointers":["/counterweights/1","/timeline/4","/timeline/5"],"sourceIds":["uksc-haworth-2025-permission","ukut-haworth-2024"],"status":"later-tax-appeal-lost","summary":"The underlying tax appeal was later dismissed through the First-tier Tribunal, Upper Tribunal and Court of Appeal; the Supreme Court refused permission to appeal."}}},"id":"haworth-v-hmrc-2021:2026-07-28.2:separate-outcomes","input":{"caseId":"haworth-v-hmrc-2021","holding":"The Supreme Court dismissed HMRC's appeal and left the follower and accelerated-payment notices quashed. The mapped record identifies two independently sufficient issue branches: the statutory threshold was not met, and HMRC had overstated the earlier authority; the second branch's separate relief step remains explicitly unmapped.","packet":{"digest":"sha256:ef195ae9951ec5aa25a2f9ecf737ac7561d1f0b91889a7003b1ea054339aec11","href":"/v1/case-commons/uk/cases/haworth-v-hmrc-2021"}},"instruction":"Separate the procedural disposition, later underlying-merits result and money meaning. Do not turn an affected demand into an award or recovery.","provenance":{"casePointers":["/counterweights/1","/financialEffect","/remedies/0","/remedies/1","/timeline/3","/timeline/4","/timeline/5"],"sourceIds":["cpr-part-44","sra-no-win-no-fee","uksc-haworth-2021-case","uksc-haworth-2021-judgment","uksc-haworth-2021-press-summary","uksc-haworth-2025-permission","ukut-haworth-2024"]},"safety":{"containsPrivateMatterFacts":false,"hiddenChainOfThought":false,"outcomePrediction":false,"qualifiedLegalReviewAsserted":false,"sourcePacketApproved":true,"taxSortedDerivedLabels":true},"schema":"taxsorted.uk.tax-dispute-training-example/1","split":"evaluation","taskFamily":"separate-outcomes"}
{"case":{"citation":"[2021] UKSC 25","id":"haworth-v-hmrc-2021","packetDigest":"sha256:ef195ae9951ec5aa25a2f9ecf737ac7561d1f0b91889a7003b1ea054339aec11","packetHref":"/v1/case-commons/uk/cases/haworth-v-hmrc-2021","slug":"haworth-v-hmrc"},"derived":{"adapter":"uk.haworth-v-hmrc-2021","frameworkVersion":"2026-07-28.2","qualifiedLegalReviewAsserted":false,"taxSortedDerivedLabels":true},"expectedOutput":{"majorChallenges":[{"blockers":[],"casePointers":["/findings/0"],"description":"The court had to determine the certainty Parliament required before HMRC could issue a penalty-backed follower notice.","evidenceNeeded":["The current statutory text","The notice","The decision-maker's contemporaneous reasoning"],"id":"challenge:statutory-threshold","impact":"Treating 'would' as mere likelihood would widen a power that could deter continuation of an appeal.","kind":"statutory-interpretation","materiality":"decisive","resolution":"HMRC's conclusion that the earlier Smallwood ruling was likely to deny the tax advantage did not meet the statutory use of 'would'. The required opinion left no scope for a reasonable person to disagree.","sourceIds":["uksc-haworth-2021-judgment","uksc-haworth-2021-press-summary"],"state":"resolved-in-decision"},{"blockers":["The canonical case record does not separately map the Senior Courts Act 1981 section 31(2A) materiality and relief step for this issue branch."],"casePointers":["/findings/1"],"description":"HMRC treated indicators in Smallwood as if they inevitably determined the result.","evidenceNeeded":["The earlier decision","The later facts and arguments","The decision-maker's account of why the cases match"],"id":"challenge:precedent-scope","impact":"The scope of the earlier ruling determined whether the statutory notice condition could be met.","kind":"authority-and-precedent","materiality":"decisive","resolution":"HMRC misdirected itself by treating seven indicators from Smallwood as inevitably locating the trust's effective management in the UK. The mapped proposition is only part of the branch; the separate relief step remains an explicit gap.","sourceIds":["uksc-haworth-2021-judgment","uksc-haworth-2021-press-summary"],"state":"bounded-by-record"},{"blockers":[],"casePointers":["/findings/2","/counterweights/2"],"description":"The penalty risk put pressure on a taxpayer to abandon an independent appeal.","evidenceNeeded":["The applicable penalty regime","The appeal route","The practical consequence of non-compliance"],"id":"challenge:access-to-justice","impact":"That practical interference supported a restrictive reading of the statutory power.","kind":"timing-and-procedure","materiality":"material","resolution":"Because the penalty risk discouraged a taxpayer from continuing an appeal, the regime interfered with access to justice and the statutory power had to be interpreted restrictively.","sourceIds":["uksc-haworth-2021-judgment","uksc-haworth-2021-press-summary"],"state":"resolved-in-decision"},{"blockers":["The packet does not reproduce every later merits issue and reason."],"casePointers":["/counterweights/0","/counterweights/1","/timeline/4","/timeline/5"],"description":"Success in reviewing the notices did not decide the separate underlying tax liability.","evidenceNeeded":["The exact order in the public-law proceedings","The complete later merits history"],"id":"challenge:procedure-versus-merits","impact":"Collapsing the two routes would turn a procedural remedy into a false claim of substantive tax success.","kind":"later-history","materiality":"material","resolution":"The notices stayed quashed, while the later underlying tax appeal failed.","sourceIds":["uksc-haworth-2021-case","uksc-haworth-2021-judgment","uksc-haworth-2025-permission","ukut-haworth-2024"],"state":"bounded-by-record"},{"blockers":["The public packet does not contain a complete net-recovery record."],"casePointers":["/financialEffect/documentedAmounts/0","/financialEffect/damagesAward","/financialEffect/netRecovery"],"description":"A large accelerated demand was affected, but it was not a damages award, refund or established net recovery.","evidenceNeeded":["Payment and repayment records","Any separate money cause of action","Costs, interest, funding and tax-on-recovery records"],"id":"challenge:money-meaning","impact":"Using the demand as a gain would materially misstate the decided remedy and financial result.","kind":"remedy-and-enforcement","materiality":"material","resolution":"£8.786m demand affected; no damages award identified; The sources identify no damages award, Mr Haworth had not paid the accelerated amount, the underlying tax appeal later failed, and this packet has no complete costs, interest, funding or tax-on-recovery record.","sourceIds":["uksc-haworth-2021-case","uksc-haworth-2021-judgment","ukut-haworth-2024"],"state":"bounded-by-record"},{"blockers":["No new person's facts or documents are accepted by this public API."],"casePointers":["/applicability"],"description":"The reasoning pattern can guide questions, but it cannot decide a new dispute without the new power, facts, route and timing.","evidenceNeeded":["The current statutory power and guidance","The complete notice and decision record","Material similarities and differences","The applicable review, appeal or judicial-review clock","Qualified matter-specific review"],"id":"challenge:transfer-to-new-facts","impact":"Uncontrolled analogy would turn historical research into unsupported legal advice or outcome prediction.","kind":"transfer-to-new-facts","materiality":"material","resolution":"A qualified assessor should first check any statutory review or appeal, then consider judicial review only where appropriate and within the applicable clock.","sourceIds":["cpr-part-54","jr-pre-action-protocol","uksc-haworth-2021-judgment"],"state":"open-for-new-case"}]},"id":"haworth-v-hmrc-2021:2026-07-28.2:identify-major-challenges","input":{"caseId":"haworth-v-hmrc-2021","dimensionStates":{"case-identity-and-tax-context":"mapped","decisive-reasoning":"partial","evidence-burden-and-standard":"partial","governing-rules-and-authorities":"partial","holding-and-disposition":"mapped","later-history-transfer-limits-and-counterfactuals":"partial","material-and-disputed-facts":"partial","party-arguments":"not-mapped","procedural-posture-and-route":"mapped","questions-and-issues":"partial","remedies-money-and-costs":"partial","supporting-and-rejected-reasoning":"partial"},"packet":{"digest":"sha256:ef195ae9951ec5aa25a2f9ecf737ac7561d1f0b91889a7003b1ea054339aec11","href":"/v1/case-commons/uk/cases/haworth-v-hmrc-2021"}},"instruction":"Identify the difficulties that materially change how the case should be read. 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