In Archer, R v HM Revenue and Customs [2017] EWCA Civ 1962 the Court of Appeal considered an appeal against the High Court decision in Archer, R v HM Revenue and Customs [2017] EWHC 296 to dismiss an application for judicial review over accelerated payment notices.

The appellant, William Archer, claimed tax losses and consequential tax relief in his 2001-02 and 2002-03 tax returns in relation to two marketed tax avoidance schemes, RDS and SHIPS, which he used in the late 1990s. In 2009 the Court of Appeal decided that neither scheme worked.