Three key cases of note in 2011 are as follows: Explainaway Ltd v HMRC in which it was held that a term that was thought to have a settled meaning was found on a purposive interpretation, when imported into a different statute, to have a different meaning; the decision of the Court of Appeal in HMRC v PA Holdings Ltd which may have fundamental consequences for much past tax planning especially for those involved in remuneration planning; and the VAT case of Paymex Ltd v HMRC, following which HMRC has published a number of briefings and notices to insolvency practitioners explaining how they would treat IVAs in future.
