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HMRC internal manual

Shares and Assets Valuation Manual

The Litigation and Technical Advice Team (LTAT): Judicial Review

Judicial review is a High Court procedure allowing individuals or groups to challenge in court the way that Ministers, Government Departments and other public bodies make administrative decisions.

Any case

  • where judicial review is mentioned as a possibility; or
  • where there is some indication that the parties are considering a challenge by legal proceedings other than via the CGT / IHT appeals procedures; or
  • where the parties argue, for example, that we must accept a certain value / valuation method as a result of an earlier official statement/alleged practice;

should be referred immediately to the LTAT.

  Additional Guidance: SVM150000