Section 85 Finance Act 2022 allows HMRC to petition to wind up a company that promotes tax avoidance schemes where it is expedient in the public interest to protect the public revenue. The court may make the order if it is ‘just and equitable’ to do so, applying the familiar test from the Insolvency Act 1986.

HMRC v Purity Limited [2025] EWHC 3401 (Ch) is the first reported use of these powers by HMRC.

Facts