Insolvency – Liquidation – Gratuitous alienation. Court of Session: In an action in which the liquidator of a company sought declarator that a payment of £200,000 the company made to the Self-Invested Personal Pension (SIPP) of one of its directors was a gratuitous alienation, and repayment of that sum, following a preliminary proof on the question whether the £200,000 was repaid to the company as the director averred the court held that it was for him to establish that he had repaid the full amount which was paid into the SIPP account, to do that he would have to demonstrate that the transfer he made had a material or patrimonial value equal to £200,000, and he had failed to do so.