UKUT 290 (2009) Goldman Sachs v HMRC

NIC planning, case management issues - taxpayer won

Case Summary:

Goldman Sachs used a NIC planning scheme. All other users had accepted HMRC’s terms. The Upper Tribunal decided that a preliminary issue, being the identity of the contributor, should be litigated first and also that the parties should argue over whether the Limitation Act applied in the County Court.

Norris J said

“I have tried to avoid being seduced by the blandishments of one side as to its willingness to settle (as to which it has yet made no concrete offer) or by the blustering intransigence of the other and its determination to litigate everything to the bitter end.”