- Considered — The Commissioners For HMRC v Bluecrest Capital Management LP & Ors 2023-12-15
“…The FTT then considered 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…”
- Cited — Thomas William Good v The Commissioners of HM Revenue And Customs 2023-02-10
“…n these arrangements and had directed that the MAPs should be paid direct to the Lender. An analogy could be drawn on the facts with RFC 2012 plc v AG Scotland [2017] UKSC 45; [2017] 4 All ER 654 at [58]-[59].…”
- Applied — Stephen Hoey & Ors. v Commissioners for HMRC 2022-05-13
“…lly contested, following 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 fo…”
- 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’…”
- Explained — The Trustees of the Morrison 2002 Maintenance Trust & Ors v Revenue And Customs 2019-02-06
“…t” was explained 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 revenu…”
- Cited — City Shoes (Wholesale) Ltd & Ors v The Commissioners for HMRC 2018-03-02
“…[2005] UKHL 47, [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…”