12 January 2026
HMRC v Purity Limited [2025] EWHC 3401 (Ch)
The High Court has made the first ever order winding up a tax avoidance promoter under section 85 FA 2022.
This is a novel power to wind up a “relevant body” (within the meaning of the Promoters of Tax Avoidance Schemes regime) if the Court is of the opinion that it is just and equitable to do so.
The Court held that it was not a requirement that HMRC must establish that the arrangements were ineffective, albeit in this case they did result in earnings because of the employee’s entitlement to the sums loaned to them.
Ben Elliott acted for HMRC.
You can read the judgment here.
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