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Although the recent case of Cameron & others v Revenue and Customs 2012 EWHC 1174 (Admin) related to the narrow area of Foreign Earnings Deduction (‘FED’) for seafarers, it is noteworthy for its wider implications for the concept of ‘legitimate expectation’ in relation to HMRC concessions, particularly where HMRC seek to alter or withdraw a concession and it may have implications for anyone relying on HMRC guidance, including those pursuing claims for capital losses on the disposal of option shares based on HMRC’s original guidance which was published following Mansworth v Jelley 2002 EWCA Civ 1829
