“…can be taken to be representative of those to whom an extra-statutory concession is directed: M.F.K., at 1569, and R (Davies) Revenue and Customs Commissioners [2011] UKSC 47, [2011] 1 WLR 2625 (“Davies”), at paragraph 29 (“the hypothetical representee is the ‘ordinarily sophisticated taxpayer’ irrespective of whether he is in recei…”
“…In R (Davies and another) v Revenue and Customs Commissioners; R (Gaines-Cooper) v Revenue and Customs Commissioners [2011] UKSC 47, [2011] 1 WLR 2625, the Supreme Court considered two judicial reviews of the Commissioners in relation to the meaning of Inland Revenue Booklet 20 (“IR20”) whi…”
“…Lord Wilson cited that last passage in R (Davies) v Revenue and Customs Commissioners [2011] UKSC 47, [2011] 1 WLR 2625 (“Davies”), in which it was…”
“…to carry within it a commitment to a group … of treatment in accordance with it ” (per Lord Wilson in R(Davies and another) v Revenue and Customs Commissioners [2011] UKSC 47 at paragraph 49). A party seeking to establish a legitimate expectation must identify…”