Rory Mullan QC represented the Claimant, Mr Sibley, in his application for permission to apply for judicial review. The issue concerned HMRC’s refusal to make a payment under the disguised remuneration settlement scheme as Mr Sibley’s loans were not outstanding at the date of the settlement (as he had to repay them as part of steps taken to fund the settlement). Mr Sibley was refused permission to appeal as the Morse Review did not inform the construction of the legislative code and HMRC’s discretion in framing the scheme was considered to be very wide. For more information on this case, please view the judgment.