The LTAG Court of Appeal hearing went ahead yesterday and was heard by Lord Justices Irwin, Henderson and Justice Mann.

As claimants we went first and had the responsibility of explaining all the necessary statutes and relevant case law.  HMRC presented after us concentrating on a few points of evidence with, surprisingly, limited attempt to explain the law.  We summed up and refuted the points of law HMRC did make.

Since we had a bulk of the responsibility to explain the law the Justices directed most of their questions at us which we believe we dealt with well.  The Justices had fewer but no less probing questions for HMRC since by that point they understood the points of law in this claim much better.

Lord Justice Henderson is probably the best tax judge at the Court of Appeal so we were pleased to have him hearing the case.  He has the reputation of wanting to understand and apply the law. Lord Justice Irwin and Mann, albeit not tax experts did engage with the hearing in a detailed, fair and even handed manner.

We understand the Court of Appeal is quite prompt in delivering their judgements. We are led to believe a judgement is likely in the next 4-12 weeks.