UK Supreme Court Decisions

Zaha Hadid Foundation v Zaha Hadid Limited - Permission to Appeal Application

The UK Supreme Court has registered a permission to appeal application in case UKSC/2026/0051, with The Zaha Hadid Foundation as the appellant and Zaha Hadid Limited as the respondent. The application was lodged on 22 April 2026 and the case originated from the PTA court. This entry reflects the initial case registration stage; no substantive ruling or decision has been issued.

HMRC v Fisher - Section 739 Income Tax Attribution: Individual as Transferor

The UK Supreme Court in HMRC v Fisher (UKSC/2021/0212, [2023] UKSC 44) has clarified the interpretation of section 739 of the Income and Corporation Taxes Act 1988 concerning offshore income attribution. The Court held that for section 739 to apply, the individual who has the power to enjoy the income must generally be the transferor of the assets; however, an individual may be treated as a transferor where the company making the transfer is one in which that individual has a controlling interest in the relevant shareholding. The appeal by Stephen and Peter Fisher and the cross-appeal by HMRC regarding Anne Fisher were heard over two days in July 2023 before the five-justice panel.

Gatwick Investment Ltd v Liberty Mutual - Business Interruption Insurance and CJRS Deduction

The UK Supreme Court (Lord Reed, Lord Briggs, Lord Hamblen, Lord Leggatt, Lord Burrows) ruled on 22 April 2026 that Coronavirus Job Retention Scheme (CJRS) payments received by employers must be taken into account (credited) when calculating amounts payable under 'savings clauses' in business interruption insurance policies. The Supreme Court reversed the Court of Appeal's decision, which had upheld the position that CJRS payments should not be deducted. The case concerned whether CJRS wage-reimbursement payments fall within policy provisions that reduce payouts when the policyholder's charges or expenses cease or reduce as a consequence of damage. Hotels and racecourse operators who claimed business interruption losses after Covid-19 and received CJRS funds will now face adjusted insurance settlements.