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HMRC lose again


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Someone on FF said that the purpose of the Supreme Court is to sit on matters that contest a point of law. Their raison d'être is not simply to handle escalated cases.

 

Unless I am mistaken, the judge in each case had and has to give leave to appeal? If the above if correct, the SC would not welcome any appeal, as for this and the last round, HMRC did not contest "a point in law", did they? Perhaps (and hopefully) the current judge sees no point to grant a leave to appeal ...

Edited by der Berliner
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Someone on FF said that the purpose of the Supreme Court is to sit on matters that contest a point of law. Their raison d'être is not simply to handle escalated cases.

 

Unless I am mistaken, the judge in each case had and has to give leave to appeal? If the above if correct, the SC would not welcome any appeal, as for this and the last round, HMRC did not contest "a point in law", did they? Perhaps (and hopefully) the current judge sees no point to grant a leave to appeal ...

 

It would certainly make it feel like the new dawn is complete. That is the last thing in our way of moving forward.

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Someone on FF said that the purpose of the Supreme Court is to sit on matters that contest a point of law. Their raison d'être is not simply to handle escalated cases.

 

Unless I am mistaken, the judge in each case had and has to give leave to appeal? If the above if correct, the SC would not welcome any appeal, as for this and the last round, HMRC did not contest "a point in law", did they? Perhaps (and hopefully) the current judge sees no point to grant a leave to appeal ...

 

You are correct that an appeal has to be on a point of law or based on new evidence (unlikely in this situation), you cannot simply reargue the original case and hope for a different outcome.

 

I am sure you are correct that the judge has to grant leave to appeal to the SC not sure if or when that applies in the lower courts.

 

I would think that 3 strikes and you're out, might apply here; even if not from a technical point of view; essentially the same point is being argued over and over again.

Edited by BrahimHemdani
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Really good news, I'd like a statement from HMRC saying they accept that all the courts have vindicated us but of course that won't happen. It will no doubt be the 'they've gotten away with it' style to try and leave it ambiguous. Nice to see us being on the right side of the law. I'll leave the morality & integrity side to the team who have a history that protected those who did break the law.

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"You are correct that an appeal has to be on a point of law or based on new evidence (unlikely in this situation), you cannot simply reargue the original case and hope for a different outcome." - BH.

 

I don't know about tax cases but in civil cases you can argue the same point of law from the Sheriff, to the Sheriff Principal to the Court of Session to the SC. By the time you get there at least four, maybe as many as nine judges will have found against you but you can win 3 - 2 in the SC. An extreme example but possible, all on a single point of law.

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"You are correct that an appeal has to be on a point of law or based on new evidence (unlikely in this situation), you cannot simply reargue the original case and hope for a different outcome." - BH.

 

I don't know about tax cases but in civil cases you can argue the same point of law from the Sheriff, to the Sheriff Principal to the Court of Session to the SC. By the time you get there at least four, maybe as many as nine judges will have found against you but you can win 3 - 2 in the SC. An extreme example but possible, all on a single point of law.

 

It would be interesting to know on what grounds leave to appeal is either granted or refused.

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Really good news, I'd like a statement from HMRC saying they accept that all the courts have vindicated us but of course that won't happen. It will no doubt be the 'they've gotten away with it' style to try and leave it ambiguous. Nice to see us being on the right side of the law. I'll leave the morality & integrity side to the team who have a history that protected those who did break the law.

 

I am hopeful, but by no means certain that what will happen here (if the rumour is correct) is the HMRC will say that they accept the verdict of the courts but will seek to have the law changed to avoid a recurrence of what TBH is a bit of a loophole, in the future.

 

On the other hand given that apparently so many other cases depend on the outcome of our case, they may still fight it all the way, on the grounds that the potential benefit to the taxpayers as a whole outweighs the cost of the court action.

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