An application for judicial review of HMRC’s decision to treat statutory clearance on a company purchase of own shares as void was refused, on the basis that an appeal to the First-tier Tribunal was a more suitable remedy.
Summary
An application for judicial review of HM Revenue and Customs’ (HMRC’s) decision to treat statutory clearance on a company purchase of own shares as void was refused, on the basis that an appeal to the First-tier Tribunal was a more suitable remedy.
Background
The first claimant (JWB) was the major shareholder in a company (the second claimant) that was the holding company of a successful trading subsidiary. When JWB had passed retirement age, it was decided that he would retire as a director to allow his son 
