36 Queen Street, London, EC4R 1BN | +44 (0)20 7242 2642
R. v. Special Commissioner of Income Tax ex parte CIR AND R v. CIR ex parte Ulster Bank Ltd – [2000] STC 537 (QBD)

This is an astonishing decision. It decides that a role apparently given to the Board of Inland Revenue can be performed by a generally authorised officer who is not a member of the Board. The point arose in the context of notices which can be served under s.20 of the Taxes Management Act and undermines the apparent safeguards in the section for notices given by the Board. The issue in this case is similar to that in ex parte Davis Frankel Mead (QB). An appeal has been lodged against this part of the decision.The good thing about Ulster Bank is that the Revenue made an agreement not to apply for consent to issue a notice after a certain date. They were held bound by this agreement. This is a most important and encouraging development even if the Judgement is somewhat grudging about the achievement.David Goldberg KC and Clive Lewis appeared for Ulster Bank Limited

Latest news:

Harry Winter promoted to B Panel and Ben Blades appointed to C Panel
Gray’s Inn Tax Chambers are delighted to announce that Harry Winter has been promoted to the Attorney General’s B Panel and Ben Blades has been appointed on the London C Panel.
29 Jul 2026
Share exchanges: just and reasonable adjustments
New legislation rewrites share exchange anti-avoidance rules
29 Apr 2026
GITC Review
Previous issues of the GITC Review are available under the ‘Articles’ Section of this website.
Read GITC review
Gray’s Inn Tax Chambers
Privacy Overview

This website uses cookies so that we can provide you with the best user experience possible. Cookie information is stored in your browser and performs functions such as recognising you when you return to our website and helping our team to understand which sections of the website you find most interesting and useful.