AC-2024-LON-001902 - [2025] EWHC 2848 (Admin)

This is the oral renewal by the tax payer (“Mr Houldsworth”) of an application for permission to bring judicial review proceedings relating to a closure notice of 8 June 2018 issued by the Defendant (“HMRC”) in respect of Mr Houldsworth’s tax affairs. The closure notice assessed Mr Houldsworth to tax of £323,528.32 on the basis that he was a UK resident for the tax year 2004/2005. That decision was upheld by an internal review at HMRC as set out in the Review Conclusion Letter of 10 October 2019.

The application for permission to appeal was received in the Administrative Court office on 6 June 2024. The application was refused on paper by Mr Justice Jay on 31 July 2025 on the following grounds:

“(1)

DELAY: no properly constituted application for an extension of time has been made and no satisfactory explanation for the delay has in any event been advanced. The Claimant’s case was always grounded on l/e and that had to be advanced by way of JR rather than before the Tribunal.

(2)

THE MERITS: the Claimant cannot point to a clear and unambiguous representation in these circumstances, particularly when the facts are in dispute. Grounds 2 and 3 add nothing”.