- Cited — The Commissioners For HMRC v Bluecrest Capital Management LP & Ors 2023-12-15
“…nsidered more case law (the decisions of the Supreme Court in RFC 2012 plc (formerly the Rangers Football Club) v Advocate General for Scotland [2017] UKSC 45, [2017] 1 WLR 2767 (“Rangers”), and the decision of the Privy Council in the New Zealand case of Hadlee v Commissioner of Inland Revenue [1993] AC 524 (“Hadlee”)), before stating…”
- Applied — Stephen Hoey & Ors. v Commissioners for HMRC 2022-05-13
“…ollowing the judgment of the Supreme Court in RFC 2012 plc (in liquidation)(formerly Rangers Football Club plc) v Advocate General for Scotland [2017] UKSC 45, [2017] 1 WLR 2767, on 12 June 2019, Mr Hoey conceded that the principle established in Rangers applied so that the amounts paid by way of EBT contributions for onward loans to h…”
- Cited — John Charman v The Commissioners for HMRC 2021-12-03
“…The authority which counsel for Mr Charman relied upon most strongly is RFC 2012 plc v Advocate General for Scotland[2017] UKSC 45, [2017] 1 WLR 2767. In order to put the passage relied upon into context, it is necessary to quote it together with several preceding paragraphs of Lord Hodge’s judgment:…”
- Cited — The Trustees of the Morrison 2002 Maintenance Trust & Ors v Revenue And Customs 2019-02-06
“… by Lord Nicholls in Barclays Mercantile Finance Ltd v Mawson [2004] UKHL 51, [2005] 1 AC 684 (see RFC 2012 plc v Advocate General for Scotland [2017] UKSC 45, [2017] 1 WLR 2767, at paragraph 12, per Lord Hodge). Ramsay, Lord Nicholls observed in the Barclays Mercantile case, had “liberated the construction of revenue statutes from bei…”
- Cited — City Shoes (Wholesale) Ltd & Ors v The Commissioners for HMRC 2018-03-02
“…[2005] STC 1111, UBS AG v Revenue and Customs Commissioners [2016] UKSC 13, [2016] 1 WLR 1005, and RFC 2012 plc v Advocate General for Scotland [2017] UKSC 45, [2017] 1 WLR 2767. But by no means all of the schemes have been litigated, and Mr Gordon told us that the schemes adopted by the present claimants were all as yet untested in th…”