Tax avoidance litigation decisions 2025 to 2026
Updated 5 November 2026
© Crown copyright 2026
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This publication is available at https://www.gov.uk/government/publications/tax-avoidance-litigation-decisions/tax-avoidance-litigation-decisions-2025-to-2026
This is a list of litigation decisions where HM Revenue and Customs (HMRC) considered tax avoidance was involved and a decision was received during 2025 to 2026. 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 also includes judicial reviews of substantive administrative actions linked to anti-avoidance legislation. Judicial reviews that do not have wider significance for other avoidance cases are not included.
Decisions on winding up petitions against the promoter of a tax avoidance schemes are also included.
1. Substantive cases
| Case name | Decision date | HMRC outcome |
|---|---|---|
| The Vaccine Research Limited Partnership and Vaughan | 04 April 2025 | Loss |
| Powell | 09 May 2025 | Win |
| Hunt and others | 12 May 2025 | Win |
| Smart | 12 June 2025 | Win |
| Osmond and Allen | 13 June 2025 | Loss |
| Marlborough DP Limited | 26 June 2025 | Win |
| Haworth and others | 01 July 2025 | Win |
| Airline Placement Limited | 23 July 2025 | Part-win[footnote 1] |
| Burley | 14 August 2025 | Win |
| Lexgreen Services Limited | 21 August 2025 | Win |
| GW Martin & Co Limited and Quadrant Surveying Limited | 25 September 2025 | Win |
| AD Bly Groundworks and CHR Travel Limited | 14 November 2025 | Win |
| Kamperis | 24 November 2025 | Win |
| Benson and others | 26 November 2025 | Win |
| Murphy and others | 01 December 2025 | Win |
| Jack | 04 December 2025 | Win |
| The Tower One St George Wharf Limited | 10 December 2025 | Win |
| Watts | 12 December 2025 | Loss |
| Wood Group Engineering (North Sea) Limited | 22 December 2025 | Win |
| O’Brien | 16 January 2026 | Win |
| Delphi Derivatives Limited (in Members’ Voluntary Liquidation | 19 January 2026 | Loss |
| Holden | 20 January 2026 | Win |
| Boston Consulting Group | 20 January 2026 | Win |
| Smith | 23 January 2026 | Win |
| Sajedi and others | 29 January 2026 | Loss[footnote 2] |
| The Executor of the Late Burles | 20 February 2026 | Win |
| UK Care No. 1 Limited | 24 February 2026 | Part-win[footnote 1] |
| Countrywide Partners Limited | 04 March 2026 | Win |
| Wood | 26 March 2026 | Win |
| Fleet | 31 March 2026 | Win |
2. Procedural cases
| Case name | Decision date | HMRC outcome |
|---|---|---|
| Scatola and others | 27 May 2025 | Win |
| Murphy | 03 June 2025 | Win |
| Sovereign Corporate Limited | 24 July 2025 | Win |
| Henley | 14 January 2026 | Part-win[footnote 1] |
| Outram and Outram | 06 February 2026 | Loss |
| King | 13 March 2026 | Win |
3. Disclosure of Tax Avoidance Schemes (DOTAS)
| Case name | Decision date | HMRC outcome |
|---|---|---|
| Hive Umbrella Limited | 17 April 2025 | Win |
| Industria Umbrella Limited | 30 April 2025 | Win |
| Industria Umbrella Limited (In Liquidation) | 17 July 2025 | Win |
| Moir Management | 10 November 2025 | Win |
| WS Vision Limited | 09 December 2025 | Win |
| PNO Group Limited (in liquidation) | 11 December 2025 | Win |
| Compliant Pay Limited | 15 December 2025 | Win |
4. Judical review
| Case name | Decision date | HMRC outcome |
|---|---|---|
| White and Laws | 27 June 2026 | Win |
| Fluid Systems Technologies (Scotland) Limited and London Fluid System Technologies Limited | 15 August 2025 | Win |
| Rokos, R (on the application of) | 26 March 2026 | Win |
5. Decisions on winding up petitions against promoters of tax avoidance schemes
| Case name | Decision date | HMRC outcome |
|---|---|---|
| Purity Limited | 23 December 2025 | Win |