[2025] EWHC 2336 (Ch)

Accordingly, I conclude that the schemes in this case were ineffective and will declare accordingly; and that the defendant is liable to pay NDR to the claimants in the sums respectively claimed, subject to my findings in relation to the specific matters identified in paragraphs 62-73 above. I invite the parties to agree a formal order, failing which a hearing will be arranged to deal with that and any other consequential matters.