- Doubted — Hugh Murphy & Anor. v The Commissioners for HMRC 2023-05-15
“…extra-statutory concession on such a basis, a taxpayer may be able to hold HMRC to it. In R v Inland Revenue Commissioners, Ex p M.F.K. Underwriting Agents Ltd [1990] 1 WLR 1545 (“M.F.K.”), Bingham LJ said at 1569, “No doubt a statement formally published by the Inland Revenue to the world might safely be regarded as binding, subject t…”
- Cited — MP, R (On the Application Of) v Secretary of State for Health And Social Care 2020-12-03
“…d devoid of relevant qualification: see the seminal decision of the Divisional Court in R. v Inland Revenue Commissioners, ex parte MFK Underwriting Agents Ltd [1990] 1 WLR 1545, at 1569 (Bingham LJ).…”
- Cited — Irish Bank Resolution Corporation Ltd v Revenue And Customs 2020-08-28
“…r because it breached a legitimate expectation: see the classic exposition by Bingham LJ in R v Inland Revenue Commissioners, ex p. MFK Underwriting Agents Ltd [1990] 1 WLR 1545, at 15691570. But in the present context HMRC was acting to give effect to primary legislation, section 11AA. That was enacted by Parliament. Even if there is …”
- Cited — JJ Management Consulting LLP & Ors v Revenue And Customs Respondents 2020-06-22
“…lic (see the statement of Mr Beighton, a member of the Board of Inland Revenue, to this effect, cited by Bingham LJ in R v IRC ex p MFK Underwriting Agents Ltd [1990] 1 WLR 1545 at 1568H). A voluntary request is much more likely to promote cooperation and collaboration and increase the possibility of avoiding hostile defensive litigati…”
- Cited — Alliance of Turkish Business People Ltd), R (on the application of) v Secretary of State for the Home Department 2020-04-28
“…[1990] 1 WLR 1545…”
- Cited — Heathrow Hub Ltd & Anor, R (On the Application Of) v The Secretary of State for Transport 2020-02-27
“…evoid of relevant qualification: see the seminal decision of the Divisional Court in R v Inland Revenue Commissioners, ex parte MFK Underwriting Agents Limited [1990] 1 WLR 1545, at 1569 (Bingham LJ).…”
- Cited — MA (Pakistan) v Secretary of State for the Home Department 2019-07-18
“… for Foreign and Commonwealth Affairs (No.2) [2009] AAAC 453 at [60], citing Bingham LJ in R v. Inland Revenue Commissioners, ex p MFK Underwriting Agents Ltd [1990 1 WLR 1545, 1569. It would require that the statement be treated as if contained within it the words, ‘even if there is a change in the law.’ It seems to me that there is…”
- Cited — Talpada, R (On the Application Of) v The Secretary of State for the Home Department 2018-04-24
“…“… ‘Unfairness’ in public law is not used in a loose general sense (R v Inland Revenue Commissioners, ex p. MFK Underwriting Agents Ltd [1990] 1 WLR 1545 at 1573B, per Judge J). Where substantive unfairness is alleged, it is necessary to show a recognised form of unfairness, such as departure from a ruling on wh…”
- Cited — City Shoes (Wholesale) Ltd & Ors v The Commissioners for HMRC 2018-03-02
“…antive unfairness had to be confined to cases of legitimate expectation falling within the principles stated in R v IRC, ex parte MFK Underwriting Agencies Ltd [1990] 1 WLR 1545, “requiring in every case an unambiguous and unqualified representation as a starting point” (see 233C). In a well-known passage, Simon Brown LJ went on to say…”