Oculus Limited, run by Maltese based director Stuart Brooke, was seeking an injunction against HMRC in a bid to quash a scheme reference number (SRN) as it argued the HMRC action would ‘decimate the business carried out by Oculus through its agent GAL’ and could result in a £1m penalty for the company.

Oculus laid six grounds of appeal for a judicial review before the High Court but only persuaded the judge that one of the grounds was reasonable.

This related to the use of HMRC form AAG6, which requires scheme promotors to provide detailed information disclosure of tax avoidance schemes to participant users and clients.