Ramsay argument fails to save taxpayer from £10m tax assessment
In B Lynch v HMRC [2025] UKFTT 300 (TC) (10 March) the First-tier Tribunal (FTT) upheld discovery assessments of just under £10m on individual steps in a failed avoidance scheme where overall there was no economic advantage. Individual steps could not be ignored where these resulted in tax being chargeable.
The taxpayer participated in a marketed tax avoidance scheme for 2010/11 to 2013/14. The scheme was notified under DOTAS.
Investors claimed deduction for interest relief on a loan to invest in a partnership (ITA 2007 s 383 and s 398). It was agreed that this aspect of the scheme was ineffective.
The scheme involved a series of steps involving sale and purchase of qualifying corporate bonds (QCBs) by a limited partnership. In HMRC’s view these individual transactions gave rise to income assessable as interest despite failure...
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Ramsay argument fails to save taxpayer from £10m tax assessment
In B Lynch v HMRC [2025] UKFTT 300 (TC) (10 March) the First-tier Tribunal (FTT) upheld discovery assessments of just under £10m on individual steps in a failed avoidance scheme where overall there was no economic advantage. Individual steps could not be ignored where these resulted in tax being chargeable.
The taxpayer participated in a marketed tax avoidance scheme for 2010/11 to 2013/14. The scheme was notified under DOTAS.
Investors claimed deduction for interest relief on a loan to invest in a partnership (ITA 2007 s 383 and s 398). It was agreed that this aspect of the scheme was ineffective.
The scheme involved a series of steps involving sale and purchase of qualifying corporate bonds (QCBs) by a limited partnership. In HMRC’s view these individual transactions gave rise to income assessable as interest despite failure...
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:
