Andrew Park critically reviews the legal battle between Matalan founder Hargreaves and HMRC

The tax saga of John Hargreaves certainly got noticed. Few individuals receive tax assessments for £84m of tax. Fewer still succeed in overturning such vast assessments at the First-Tier Tax Tribunal (FTT). However, in the interim between the FTT decision and the appeal to the Upper Tribunal – J Hargreaves v HMRC [2022] UKUT 34 (TCC) - the legal ground shifted beneath the taxpayer’s feet.

What were the facts?

The entrepreneur behind Matalan had sold c.£231m of shares in the company in May 2000 – at a time when he considered himself to have recently become a non-UK resident denizen of Monaco. Most of the potential liability – some £80m of it – was to Capit...

Andrew Park
Tax Investigations Partner
Andersen in the UK

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