And also quite amusing. See para 61 (ii):
I don’t understand why £7k p.a. ATED was paid per para 96(iii), as it seems the company owned the property (at least from 1995 – see below) merely as a nominee (i.e. as trustee for the human beneficial owner of the shares) and the Defendant’s counsel at para 107 and the Defendant at para 121 agree with that, as does the Claimant’s counsel and indeed the judge at para 116.
The Single Joint tax Expert seems to have overlooked all that re ATED. Maybe they can apply for a refund?
Interestingly, the UK Ltd online accounts show the company was the BO originally and disposed of the property in 1995 (the judgment glosses over that).
The case also shows the perils of DIY legal drafting (which with rather delicious irony resulted in more or less the precise outcome he had thereby planned to avoid).