In R oao J Boulting and another v HMRC [2020] EWHC 2207 (Admin) (12 August 2020) the High Court refused the taxpayer’s application for judicial review of HMRC’s decision to void the statutory clearance it had given on a purchase by an unquoted trading company of its own shares.
PSC Training and Development Group Limited (the Company) had applied for and received clearance that its buyback of shares would be treated as a capital transaction in...