A number of taxpayers who received advanced payment notices (APNs) or partner payment notices (PPNs) have challenged those notices by way of judicial review. The Court of Appeal dismissed the taxpayers' appeals, finding that the APNs and PPNs in question were neither ultra vires, unreasonable nor contrary to human rights.

Interestingly, the judgment in this case leaves some uncertainty of whether the same decision would be reached in a situation where the taxpayer faced financial hardship as a result of receiving an APN or PPN and this may leave the door open for a future challenge, although it was intimated that the level of hardship would have to be severe.