Biffin and others v HMRC

Cathya Djanogly

In Biffin and others v HMRC [2016] EWHC 2926 (13 October 2016) the High Court found that it had jurisdiction to hear the case and granted an injunction prohibiting HMRC from commencing enforcement action in respect of tax liabilities.

This was an application by three claimants for an interim injunction prohibiting HMRC from commencing enforcement action against them in respect of alleged tax liabilities that were the subject of appeal and postponement applications before the FTT. The dispute concerned the purchase and sale of property and the tax at stake was over £10m. The claimants had also applied for judicial review of several decisions of HMRC including amendments to the company’s and its directors’ tax returns; the refusal to agree the postponement of the tax demanded under jeopardy amendments; and finally the decision to start insolvency proceedings against the company.

The High Court found that...

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