09 December 2025
Benson & Ors v HMRC [2025] UKFTT 1442 (TC)
The FTT has dismissed the appeals in Benson & others v HMRC [2025] UKFTT 1442 (TC).
These were the lead appeals in a widely-used contractor loan scheme with over 700 users. The FTT considered a number of procedural and substantive issues, including the scope of HMRC’s closure notices, arguments concerning the FTT’s jurisdiction and estoppel, the application of the agency legislation and whether the Isle of Man company the taxpayers had contracted with had a UK tax presence, with all issues decided in HMRC’s favour.
Sadiya Choudhury KC leading Colm Kelly of Devereux Chambers acted for HMRC.
You can read a copy of the judgment here.
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