About Us

The Care Action Group is a trading style of Cowgills Whittle Limited, a company regulated by The Institute of Chartered Accountants in England and Wales. The company was formed with the sole purpose of pursing a Judicial Review action against HMRC on behalf of residential care operators.

The purpose is to recover all VAT incurred by residential care operators over several decades, with further redress to include interest. The sums involved are, therefore, very substantial, typically amounting to six figures for a single care home operator.



The Care Action Group Newsroom

Welcome to The Care Action Group Newsroom! The Newsroom is the focal point of the website where we will keep you up to date with the Judicial Review process as it unfolds.

After reading the update, Residential care operators are advised to watch the video below for a full and detailed background to The Care Action Group and the Judicial Review process – it should answer many questions you may have.

Further updates will be posted as and when they occur. All clients of The Care Action Group will receive an email alert immediately as the Newsroom is updated.

Latest Update – July 2026

We now have a relisting hearing scheduled for 15 December 2026.

A significant advantage of this timetable is that it gives HMRC additional time to consider our full Skeleton Argument. The argument sets out HMRC’s crucial mistake and its departure from official policy, together with the wider implications of that position, including the denial of input tax recovery for the worthy community of qualifying residential care operators.

In light of these developments, we reiterate our view that qualifying residential care operators that are not already registered with the Group should consider joining now.

Update – May 2026

With only 3 days prior notice, the Upper Tax Chamber delayed the Hearing scheduled for the 13 May (see email below) which is incredibly frustrating for us all. Our instructing Solicitor is liaising with HMRC and the Upper Tribunal to agree on a date for the rescheduled Hearing, which will be posted here as soon as we have it.

Dear Sirs / Madams

With regret and the sincere apologies of the Tribunal. Due to unforeseen circumstances Judge Scott has had to withdraw from the Hearing next week and we do not have another qualified Judge available on the 13th.

We would hope to be able to relist as soon as possible and would ask the Parties to liaise and advise of any mutual dates as soon as possible.

Yours faithfully

Tribunal Clerk

Upper Tribunal (Tax and Chancery) | HMCTS | 5th Floor, Rolls Building, Fetter Lane | London | EC4A 1NL

Update – February 2026

The matter has now been listed for a Permission Hearing on 13th May 2026 before JUDGE THOMAS SCOTT. This is the first time we have had the opportunity to address Judge Scott directly and aligns perfectly with the final completion of our multiyear research.

We look forward to the Hearing with eager anticipation and are primed to demonstrate to the Court and HMRC the fundamental mistake made that has been so costly to the residential care sector.

Update – October 2025

Good news! JUDGE THOMAS SCOTT has been assigned to the case. he has immediately apologised for the delay and undertaken to expedite matters.

Update – June 2025

There is a backlog of cases within the Upper Tribunal Tax and Chancery Chamber, and so, we are using this interval to strategically and assertively strengthen our position and push matters forward.

To achieve this, we recently met in conference with our lead Counsel, Roderick Cordara KC, to finalise an additional and highly substantive submission to the UTTC. This latest document includes fresh analysis and critical intelligence that significantly reinforces our claims.

This new submission advocates that, in all the circumstances, a separate permission hearing should be dispensed with—potentially accelerating the entire process. Based on current expectations, we anticipate that the timetable for a full hearing could now fall toward the end of 2025.

The submission has been formally lodged, and both Counsel and our legal team believe it represents a powerful statement of the strength and depth of our case.

Background To The Case

If you are new to The Care Action Group, we encourage you to watch the video below. It offers a comprehensive overview of our mission, the Judicial Review process, and what you can expect. It should answer many of your initial questions.