In the First-Tier Tribunal Tax Chamber, Rory Mullan QC acted for the Respondents, AML Tax (UK) Limited and Denmedical UK Limited. HMRC claimed that the Respondents promoted tax avoidance arrangements called split contracts, which were not properly notified. The court agreed with the HMRC, ruling that the arrangements were notifiable and both appellants were promoters of the arrangements. The arrangements were notifiable since they; enabled a scheme user to have obtained a tax advantage; the main benefit or one of the main benefits that might be expected to arise from the arrangements was the obtaining of that tax advantage; the arrangements met the premium fee hallmark and, as regards Denmedical, the standardised product hallmark too; and, in respect of the latter, were not safe harboured. For these reasons, the court granted the Application and made the orders sought by HMRC under both section 314 A and section 306 A FA 2004 in respect of both appellants. For more information on this case, please view the judgment.