Home / Private Client / Tax avoidance, evasion and non-compliance / Offshore tax evasion

Legal News

Judicial review—publication of scheme promoter's details would not contravene EU-law-derived rights (R (oao Vision HR Solutions) v HMRC; R (oao Veqta Ltd) v HMRC)

Copyright © 2025 LexisNexis

Published on: 04 August 2023

Published by a LexisNexis Private Client expert

imgtext

Article summary

Private Client analysis: The claimants sought judicial review of a decision to list their details pursuant to section 86 of the Finance Act 2022 (FA 2022). The Administrative Court, in dismissing their renewed application for permission, held that FA 2022, s 86 constituted neither—(1) a breach of any right to free movement of capital; (2) a breach of any right to freedom of establishment; or (3) a breach of the Human Rights Act 1998 (HRA 1998) or Article 1, Protocol 1 of the European Convention on Human Rights (ECHR). This decision provides a useful analysis of the extent to which formerly applicable rights derived from EU law are no longer available under domestic law, and serves as a reminder of the difficulties faced by those whose claims for judicial review amount to a request for the court to review primary legislation. Written by Harry Smith, senior associate...

Popular documents

What is the difference between an appeal and a review?

What is the difference between an appeal and a review?What is an appeal?An appeal in insolvency proceedings is no different to an appeal in normal litigation. An appeal will be allowed only if the appeal court is satisfied that the decision of the lower court was 'wrong' or 'unjust because of a

Late payment penalties—inheritance tax

Late payment penalties—inheritance taxWhile interest often accrues on overdue tax, the late payment of certain taxes may also attract a penalty. For information on the interest accruing on overdue tax, see Practice Notes: IHT—payment deadlines on death—Interest on IHT and Interest on late paid

Can shares in a limited company that have not been paid-up at all be cancelled?

Can shares in a limited company that have not been paid-up at all be cancelled?A limited company having a share capital may not alter that share capital, except in the ways listed in section 617 of the Companies Act 2006 (CA 2006). Shares in a company cannot simply be cancelled without following an

Template for regulatory references given by SMCR firms and disclosure requirements

Template for regulatory references given by SMCR firms and disclosure requirements[Insert addressee details]Dear [insert name][It is our understanding that [insert name of prospective employee] [was an employee of yours between the dates of [insert dates as appropriate] OR is a current employee of