In the Court of Appeal Civil Division, Rory Mullan QC acted for the Claimants / Appellant, including Mr. Hoey. This case involved HMRC’s efforts to collect PAYE income from individual employees by use of a power in section 684(7A)(b) ITEPA 2003. It also raised issues as to when payments made as part of tax avoidance arrangements are deductible on grounds that they are wholly and exclusively for the purposes of a trade; and as to the application of the transfer of assets abroad code in the context of services provided by an individual. The court dismissed the appeal on the PAYE points but found for the taxpayers in relation to both the deductibility of payments made in the course of a tax avoidance scheme and the application of the transfer of assets abroad code. For more information on this case, please view the judgment.