CR-2025-001323 - [2025] EWHC 2297 (Ch)

IN THE HIGH COURT OF JUSTICE

CHANCERY DIVISION

BUSINESS AND PROPERTY COURTS OF ENGLAND AND WALES

Royal Courts of Justice, Rolls Building

Fetter Lane, London, EC4A 1NL

Before :

MR JUSTICE HILDYARD

Between :

Mr. Daniel Bayfield KC and Ms. Charlotte Cooke (instructed by White and Case LLP)

for the Plan Company

Mr. Matthew Abraham and Ms. Annabelle Wang (instructed by Milbank LLP)

for the SteerCo

Mr. Jon Colclough (instructed by Mayer Brown International LLP) for the

Capricorn Companies

Mr. Stefan Ramel (instructed by HMRC) for His Majesty’s Revenue and Customs

Hearing date: Friday 29 August 2025

Approved Judgment

This judgment was handed down remotely at 10.30am on 9 September 2025 by circulation to the parties or their representatives by e-mail and by release to the National Archives.

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MR JUSTICE HILDYARD