Court of in Hoey v HMRC
The Court of appeal has handed down judgment in the joined Hoey v HMRC appeals. Rory Mullan KC appeared for the taxpayers.
The Court found that HMRC could lawfully exercise a discretion with the effect of transferring liability to pay PAYE to employees. It also held that this liability was not a matter for the tax Tribunals. Finally, it dismissed HMRC’s appeals that an alternative charge under the transfer of assets abroad legislation applied.
The decision can be found here.
