England and Wales Case Law

The Commissioners for HMRC v Purity Limited

It is just and equitable to wind up Purity Limited in the public interest under section 85 of the Finance Act 2022 due to substantial detriment to public revenue, lack of transparency, and continuation of a previous tax avoidance business, and compulsory liquidation is appropriate despite existing voluntary liquidation to ensure proper investigation and deterrence.

Source excerpt

• Public interest winding up
• Tax avoidance schemes
• Promoters of tax avoidance
• Creditors' voluntary liquidation
• Compulsory liquidation

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The Commissioners for His Majesty's Revenue And Customs v Purity Limited

The Commissioners for His Majesty's Revenue And Customs v Purity Limited [2025] EWHC 3401 (Ch) (23 December 2025)

HMRC obtained a public interest winding-up order against Purity Limited under section 85 of the Finance Act 2022 for operating a tax-avoidance scheme.

• Public interest winding up
• Tax avoidance schemes
• Finance act 2022 s.85
• Promoters of tax avoidance
• Paye and nic liabilities
• Creditors' voluntary liquidation

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Commissioners for His Majesty's Revenue and Customs v Purity Ltd

Commissioners for His Majesty's Revenue and Customs v Purity Ltd [2024] EWHC 2965 (Ch) (22 November 2024)

The High Court refused Purity Limited’s stay application in HMRC’s public interest winding-up petition, holding public law defences could be raised in the petition proceedings.

• Public interest winding up
• Judicial review
• Public law defences
• Tax avoidance schemes
• Statutory interpretation
• Public-interest-winding-up

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Secretary of State for Business Energy And Industrial Strategy v Sentor Solutions Commercial Ltd & Ors

Secretary of State for Business Energy And Industrial Strategy v Sentor Solutions Commercial Ltd & Ors [2022] EWHC 2734 (Ch) (31 October 2022)

The High Court ordered four companies wound up in the public interest after finding an investment fraud, lack of FCA authorisation, poor records, and no cooperation.

• Public interest winding up
• Investment fraud
• Lack of commercial probity
• Failure to keep accounting records
• Lack of transparency
• Fca authorisation

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Secretary of State for Business, Energy And Industrial Strategy v Vanguard Insolvency & Ors

Secretary of State for Business, Energy And Industrial Strategy v Vanguard Insolvency & Ors [2022] EWHC 1589 (Ch) (12 May 2022)

The High Court granted public interest winding-up petitions against four companies linked to IVA work after finding opaque payments, undisclosed benefits, and breach of SIP 9.

• Public interest winding up
• Lack of commercial probity
• Transparency in insolvency practice
• Breach of statement of insolvency practice (sip 9)
• Undisclosed commissions
• Trust monies misuse

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SECRETARY OF STATE FOR BUSINESS, ENERGY AND INDUSTRIAL STRATEGY v VANGUARD INSOLVENCY & Ors

The High Court ordered four related companies wound up in the public interest after finding a lack of commercial probity and transparency in IVA-related payments.

• Public interest winding up
• Lack of commercial probity
• Transparency in insolvency practice
• Breach of statement of insolvency practice 9 (sip 9)
• Public-interest-winding-up
• Insolvency-practice

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The Secretary of State for Business, Energy And Industrial Strategy v PAG Asset Preservation Ltd

The Secretary of State for Business, Energy And Industrial Strategy v PAG Asset Preservation Ltd [2020] EWCA Civ 1017 (31 July 2020)

The Court of Appeal dismissed appeals over a business-rates avoidance scheme, holding Scheme 3 was not a misuse of insolvency law and did not justify winding up.

• Winding up on public interest grounds
• Business rates avoidance schemes
• Members' voluntary liquidation (mvl)
• Misuse of insolvency legislation
• Commercial probity
• Artificial transactions

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The Secretary of State for Business, Enterprise and Industrial Strategy v Viceroy Jones New Tech Ltd & Ors

The Secretary of State for Business, Enterprise and Industrial Strategy v Viceroy Jones New Tech Ltd & Ors [2020] EWHC 1155 (Ch) (12 May 2020)

The High Court made a non-party costs order and Bathampton order against George Frost after finding he controlled and benefited from a truffle-tree investment scheme.

• Non-party costs orders
• Public interest winding up
• Director liability
• Abuse of limited liability
• Bathampton order
• Non-party-costs-orders

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Secretary of State for Business, Energy and Industrial Strategy v PAG Asset Preservation Ltd

The High Court dismissed petitions to wind up two companies used in a business rates avoidance scheme, holding the scheme did not misuse insolvency law.

• Public interest winding up
• Members' voluntary liquidation (mvl)
• Business rates avoidance
• Commercial probity
• Abuse of insolvency process
• Public-interest-winding-up

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Secretary of State for Business, Energy and Industrial Strategy v PAG Asset Preservation Ltd

Secretary of State for Business, Energy and Industrial Strategy v PAG Asset Preservation Ltd [2019] EWHC 2890 (Ch) (30 October 2019)

The High Court dismissed public interest winding-up petitions against two companies operating a business rates avoidance scheme through MVLs.

• Public interest winding up
• Business rates avoidance
• Members' voluntary liquidation (mvl)
• Corporate probity
• Purpose of insolvency legislation
• Public-interest-winding-up

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