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Vision HR Solutions Ltd and another v HMRC

Publication of disguised remuneration scheme information.

In R (o.a.o. Vision HR Solutions Ltd) v HMRC; R (o.a.o. Veqta Ltd) v HMRC [2023] EWHC 1659 (3 July) the High Court held that publication of information about disguised remuneration scheme did not contravene EU freedoms of movement of capital and establishment and that HMRC's decision to exercise such powers did not contravene human rights law.

The claimants raised the judicial review challenge against HMRC’s decision to exercise its powers under FA 2022 s 86 and publish information about a disguised remuneration scheme they had marketed. The grounds for the review included that publication of this information was an unjustified and disproportionate infringement of the right to free movement of capital and also that publication would interfere with their human rights.

The High Court refused the claimants’ applications for judicial review finding that FA 2022 s 86 is...

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