“…the challenges had been successful. Apart from Rowe, the cases to which the judge referred were R (Walapu) v HMRC [2016] EWHC 658 (Admin), R (Dickinson) v HMRC [2017] EWHC 1705 (Admin), [2017] 4 WLR 126, and the decisions of the High Court and this court in relation to what the judge called a “similar regime for countering tax avoidance also …”
“…The reference to the judge’s judgment is [2017] EWHC 1705 (Admin); the judgment is available on the BAILII website. I return to the judge’s salient reasoning and conclusions below. On this appeal, the claimants argue that the…”