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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 QC and Clive Lewis appeared for Ulster Bank Limited

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