In Trustees of Panico Panayi A&M Settlements and Redevco Properties UK v HMRC [2026] EWCA Civ 744, the Court of Appeal (CoA) upheld the Upper Tribunal's decision that, by way of a conforming interpretation, UK legislation could be read as permitting exit tax liabilities to be paid in five equal annual instalments when the taxpayers moved their tax residences abroad.









