Tax avoidance litigation decisions 2024 to 2025
Updated 17 July 2025
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This publication is available at https://www.gov.uk/government/publications/tax-avoidance-litigation-decisions/tax-avoidance-litigation-decisions-2023-to-2024
This is a list of litigation decisions where HM Revenue and Customs (HMRC) considered tax avoidance was involved and a decision was received during 2024 to 2025. Some decisions may be subject to further appeal.
The decisions are split between cases where the substantive issue considered was tax avoidance, those which relate to procedural rules that have a wider application to other avoidance cases and those which relate to the Disclosure of Tax Avoidance Schemes (DOTAS) legislation.
The list includes decisions specifically related to HMRC’s ongoing activity to name tax avoidance schemes, promoters and enablers. This is the only section which includes published court decisions on whether to grant permission for a judicial review challenge to proceed to a full hearing.
The list also includes judicial reviews of substantive administrative actions linked to anti-avoidance legislation.
Decisions about procedural rules and judicial reviews that do not have wider significance for other avoidance cases are not included.
1. Substantive cases
2. Procedural cases
| Case name | Decision date | HMRC outcome |
|---|---|---|
| Labeikis and others | 7 August 2024 | Win |
3. Disclosure of Tax Avoidance Schemes (DOTAS)
| Case name | Decision date | HMRC outcome |
|---|---|---|
| Countrywide Partners Ltd | 11 April 2024 | Win |
| Asset House Piccadilly Limited | 12 February 2025 | Win |
| Saxonside Limited | 21 February 2025 | Win |
4. Judicial review
| Case name | Decision date | HMRC outcome |
|---|---|---|
| Refinitiv Limited and others | 15 November 2024 | Win |
5. Published decisions on permission for judicial review on publishing tax avoidance schemes, promoters, enablers and suppliers
| Case name | Decision date | HMRC outcome |
|---|---|---|
| Payeworx Limited, R (on the application of) | 8 November 2024 | Win |
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Part-win: decision where substantive elements of HMRC’s case succeeded. ↩
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This is a strike out decision. The court has the power to strike out (such as ‘dismiss’) either party’s entire case (as occurred here) or parts of it prior to the appeal proceeding to a full hearing. A strike out, depending on which issues in dispute are struck out, can end a set of proceedings. ↩