Double taxation – Relief. The defendant Revenue and Customs Commissioners (HMRC) had applied the principles and reasoning of Re the Trevor Smallwood Trust; Smallwood and another v Revenue and Customs Commissioners ([2010] All ER (D) 99 (Jul)) to the documents, evidence and representations in the claimant taxpayer's case to determine whether there had been a scheme of management controlled from the UK which would deny the asserted advantage. The Administrative Court rejected the taxpayer's further arguments, and dismissed his claim for judicial review of the issue of a follower notice and an accelerated payment notice in relation to gains arising to the trustees of a settlement from the disposal of assets.