“…The claim for judicial review was decided by Jay J on 21 February 2017 ([2017] EWHC 296 (Admin), [2017] 1 WLR 2066). In the judicial review, the appellant was represented by David Goldberg QC and Conrad McDonnell, and HMRC were represented by Aparna Nathan and Marika Lemos.…”
“…This provision was considered by Mr Justice Jay in the High Court ([2017] EWHC 296, [2017] 1 WLR 2066) and this court on appeal, in R (Archer) v HMRC[2017] EWCA Civ 1962, [2018] 1 WLR 5210. Judgment in the High Court was in fact handed down in Archer a month be…”