Supreme Court favours narrow interpretation of ICTA 1988 finding that the shareholders were not the transferors of assets under TAA Code (Revenue and Customs Commissioners v Fisher and another; Revenue and Customs Commissioners v Fisher No 2)

Published on: 21 November 2023

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Article summary

In Revenue and Customs Commissioners v Fisher and another; Revenue and Customs Commissioners v Fisher No 2, the Supreme Court unanimously allowed the shareholders’ appeal and dismissed HMRC’s appeal holding that the shareholders were not singly or collectively the transferors of the betting operations business that was sold by the UK company to the Gibraltar company for the purposes of the transfer of assets abroad code (TAA Code).

Jurisdiction(s): England and Wales

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