“…aim even if it proceeds to a full substantive judicial review hearing: R (Glencore Energy UK Limited) v Revenue and Customs Commissioners [2017] EWCA Civ 1716, [2017] 4 WLR 213 [52]-[58], [71] (Sales LJ).…”
“…er the Finance Act 2015 (“FA 2015”), in R (Glencore Energy UK Ltd) vHMRC [2017] EWHC 1476 (Admin), [2017] STC 1824, approved on appeal at [2017] EWCA Civ 1716, [2017] 4 WLR 213. As the judge said at [29], the main challenges in Rowe and in Walapu were on general public law grounds, including the alleged incompatibility of the APN syst…”