Company
Revenue and Customs Commissioners v Purity Ltd [2025] EWHC 3401 (Ch)
The Chancery Division granted HMRC's winding-up petition against Purity Ltd, the first such petition presented under s 85, Finance Act 2022, which permits HMRC to seek the winding-up of tax avoidance scheme promoters when it is expedient in the public interest for the protection of public revenue. The court found Purity was a ‘relevant body’ under s 85 and that it was just and equitable to wind up the company on three grounds: first, Purity's tax avoidance scheme caused substantial tax loss; second, Purity demonstrated lack of transparency to both employees and HMRC; and third, Purity represented a continuation of a similar business previously conducted by Alpha Republic Ltd, which had also been liquidated following HMRC investigation. The court determined that compulsory liquidation was appropriate despite Purity already being in creditors' voluntary liquidation, emphasising the need for full investigation by independent office-holders and to send a clear message to tax avoidance scheme promoters.
Costs
R v Jacob (formerly Oyemola)
