In this blog, which is based on an article published in Tax Journal on 23 April 2025, we consider the appropriate mechanism to challenge decisions taken by HMRC’s debt management team.
Introduction
In Local Fuel Ltd v HMRC [2025] EWHC 390 (Ch), the High Court considered an application by HMRC to strike out Local Fuel Ltd’s (LFL) Part 8, Civil Procedure Rules (CPR) claim, as an abuse of process, on the basis that HMRC’s decision to enforce a debt constituted a public law decision which could only be challenged by way of judicial review proceedings, with the restrictive time limits and permission requirements that apply in such proceedings. The High Court dismissed HMRC’s application and…
