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 primary legislation enacted after Brexit...
