David Whiscombe asks whether it is fair for a taxpayer to be effectively taxed twice on the basis of a mutually exclusive analysis of the same transaction.
This is the sad tale of Mr Jones (names have been changed).
Mr Jones was a consultant operating through his own company Jones Ltd.
His director’s loan account (‘DLA’) had become overdrawn and tax under (what is now) CTA 2010 s 455 had been paid. In January 2014 having been assured that it was all above-board and approved by HMRC etc. he and Jones Ltd signed up to a scheme which purported to create a £250 000 credit to the DLA without creating any charge to tax. This as it turned out was the ‘second hand bond’ scheme on which the GAAR Advisory Panel was eventually to express its opinion on 12 April 2019.
Accounts and tax...
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David Whiscombe asks whether it is fair for a taxpayer to be effectively taxed twice on the basis of a mutually exclusive analysis of the same transaction.
This is the sad tale of Mr Jones (names have been changed).
Mr Jones was a consultant operating through his own company Jones Ltd.
His director’s loan account (‘DLA’) had become overdrawn and tax under (what is now) CTA 2010 s 455 had been paid. In January 2014 having been assured that it was all above-board and approved by HMRC etc. he and Jones Ltd signed up to a scheme which purported to create a £250 000 credit to the DLA without creating any charge to tax. This as it turned out was the ‘second hand bond’ scheme on which the GAAR Advisory Panel was eventually to express its opinion on 12 April 2019.
Accounts and tax...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
