“…Section 18 was considered by the Supreme Court in R (Ingenious Media Holdings plc) v Revenue and Customs Commissioners [2016] UKSC 54, [2016]1 WLR 4164. The Court acknowledged the general and long-established principle of confidentiality owed to taxpayers (at [22]). Lord Toulson, with whom th…”
“…wer to disclose the Disputed Documents to Mr Bell without Mr Mitchell’s consent, citing section 18 CRCA and R (Ingenious Media Holdings plc and another) v HMRC [2016] UKSC 54. In response, she said that:…”
“…ed on the executive to modify primary legislation, it should be resolved by a restrictive approach. Mr Segan QC also relied upon R (Ingenious Media plc) v HMRC [2016] UKSC 54; [2016] 1 WLR 4164 at [19]-[20] per Lord Toulson JSC and J v Welsh Ministers [2018] UKSC 66; [2019] 2 WLR 82 at [24] per Baroness Hale of Richmond PSC.…”