AC-2024-LON-001976 - [2025] EWHC 2479 (Admin)

I am considering a renewed application for judicial review brought by the Claimant, Aubrey Weis, against the decision of His Majesty’s Revenue and Customs (“HMRC”) to issue a series of ‘closure notices’ for the years between 2005-2013 and uphold them on statutory review on 17 November 2021. The conclusion of the statutory review was that Mr Weis was domiciled in the United Kingdom and not Israel, with the effect that his non-United Kingdom source income would be subject to United Kingdom tax for the relevant tax years.

Permission to pursue this judicial review claim was refused on the papers by Jay J. The primary reason given was that the claim was brought substantially out of time and there was no good reason to extend time. Jay J also stated for completeness that the judicial review claim, which was based on the public law principle of legitimate expectation, was unarguable.

I have to consider whether to extend time, and whether to grant permission for the Claimant to proceed with his judicial review claim.