Michael Avient and Heather Williams (UHY Hacker Young) review the recent decision in Degorce, one of a group of cases which will have a major impact on ‘trading’ structures.
The decision in the appeal of Degorce v HMRC [2015] UKUT 447 (reported in Tax Journal 11 September 2015) marks another success for HMRC in its campaign to tackle what it regards as abusive tax avoidance. However like other decisions in its favour the case fails to provide HMRC with the magic bullet that would allow it to knock down all the current tax loss schemes either being investigated or litigated.
HMRC’s current view in respect of marketed tax loss avoidance schemes can be traced back to the early noughties when the Inland Revenue (as it was) realised that these marketed schemes relied upon expenditure where the taxpayer was not necessarily financially at...
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Michael Avient and Heather Williams (UHY Hacker Young) review the recent decision in Degorce, one of a group of cases which will have a major impact on ‘trading’ structures.
The decision in the appeal of Degorce v HMRC [2015] UKUT 447 (reported in Tax Journal 11 September 2015) marks another success for HMRC in its campaign to tackle what it regards as abusive tax avoidance. However like other decisions in its favour the case fails to provide HMRC with the magic bullet that would allow it to knock down all the current tax loss schemes either being investigated or litigated.
HMRC’s current view in respect of marketed tax loss avoidance schemes can be traced back to the early noughties when the Inland Revenue (as it was) realised that these marketed schemes relied upon expenditure where the taxpayer was not necessarily financially at...
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:
