The LTAG Appeal to the Supreme Court was formally submitted today.

In prior hearings at the High Court and at the Court of Appeal, we had to be quite circumspect about what we said since we could not bring into question a prior judgement of the Supreme Court in lower courts.  This brake has now been released.

Our Appeal raises questions of general and serious importance as to the scope of HMRC’s powers and the way some of the most basic parts of the tax code (those that create debts in HMRC’s favour) work.  These questions are relevant to huge numbers of taxpayers and the implications go far beyond those involved in historic tax planning.

We feel our Appeal is very strong and puts forwards arguments HMRC and the Supreme Court Justices will have to think carefully over.

The next step will be to for the Supreme Court to let us know if we have been granted the right to Appeal.  Prior to that they will seek a defence of our Appeal from HMRC.

Given the current lockdown we expect a decision on our Appeal to be in the 6-12months timeframe but we really cannot be sure.