Serle Court is delighted that the case of HMRC v IGE USA Investments has been featured by ITR EMEA Tax Awards 2021 in their ‘Impact Cases of the Year’. Philip Jones QC, Gareth Tilley and Max Marenbon acted on behalf of HM Revenue & Customs.

This case was a complex case concerning the validity of a clearance of a scheme of loan transactions under the Anti-Arbitrage and Unallowable Purpose Rules. The case resulted in a number of reported decisions including on the interpretation of the Disclosure Pilot Scheme and the question whether rescission of a contract for fraudulent misrepresentation in equity carries a limitation period by analogy with the tort of deceit (on which question leave was granted to appeal to the Supreme Court). 

The case has recently reached a settlement.