Corporate report

Tax avoidance litigation decisions 2024 to 2025

Updated 17 July 2025

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

Case name Decision date HMRC outcome
BlackRock HoldCo 5, LLC 11 April 2024 Win
Marlborough DP Limited [footnote 1] 12 April 2024 Win
Hargreaves Property Holdings Limited 15 April 2024 Win
A D Bly Groundworks and others 22 April 2024 Win
Kwik-Fit Group Limited and others 3 May 2024 Win
Osmond and Allen 8 May 2024 Win
Burlington Loan Management DAC 31 May 2024 Loss
Watts 12 June 2024 Win
JTI Acquisition Company (2011) Limited 13 June 2024 Win
Moore 13 June 2024 Win
Murphy 13 June 2024 Win
UK Care No 1 Limited 13 June 2024 Win
Altrad Services Limited and Robert Wiseman and Sons Limited 28 June 2024 Win
HFFX LLP and others 19 July 2024 Win
Brindleyplace Holdings S.À R.L 6 September 2024 Loss
Greene 26 September 2024 Win
GCH Corporation Ltd and others 17 October 2024 Loss
Murphy and Murphy 17 October 2024 Win
G Goldsmith Limited and Goldsmith 18 October 2024 Part-win [footnote 2]
Ray 22 October 2024 Win
Equity Advisory Limited and Mellor 24 October 2024 Win
Syngenta Holdings Limited 1 November 2024 Win
R (on application of Cobalt Data 2 Centre LLP and another) 20 November 2024 Win
The Tower One St George Wharf Limited 20 November 2024 Win
Grint 25 November 2024 Win
Hoyle and others 26 November 2024 Loss
Simrajsar Limited and Achilles Products Limited 28 November 2024 Win
Blackfriars Hotel (UK) Holdings Limited 6 December 2024 Win
Harvey and Keswick Enterprises Holdings Charitable Trust 6 December 2024 Win
M R Currell Limited 6 December 2024 Loss
Robinson and McAllister [footnote 3] 3 January 2025 Win
Lloyds Asset Leasing Limited 20 January 2025 Win
Homewood 22 January 2025 Win
The Executors of Elborne and others 17 February 2025 Loss
LR R&D LLP 28 February 2025 Win
Sajedi and others 6 March 2025 Win
Lynch 10 March 2025 Win

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
  1. A supplemental decision has also been published

  2. Part-win: decision where substantive elements of HMRC’s case succeeded. 

  3. 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.