The Court ruled that appellants Sharon Clipperton and Steven Lloyd had used a marketed tax avoidance scheme called Aikido, which was designed to enable the owners of a company to extract funds from the company without incurring a charge to income tax.  

Clipperton and Lloyd each held 50% of the shares in Winn & Co (Yorkshire) Ltd, which provided accounting services, and in 2012 were sole directors.

This case centred around the use of the Aikido scheme in 2012 and whether it amounted to tax avoidance.