Sabina Margulies (Lexis®PSL Tax) reviews lessons from the Court of Appeal judgment.
The Court of Appeal decision in Haworth [2019] EWCA Civ 747 is a rarity in that the taxpayer was successful in challenging the validity of the follower notice (FN) and the accelerated payment notice (APN) based on it. Both notices were quashed.
In its decision the Court of Appeal provides useful guidance on interpreting FA 2014 s 205(3)(b) which is one of the conditions required for a judicial ruling to be ‘relevant’ to another taxpayer’s tax arrangements for the purpose of issuing an FN to that taxpayer.
What was the background?
Mr Haworth entered into a set of arrangements known as a ‘round the world’ tax scheme in 2000/01 under which he sought to avoid UK capital gains tax arising on the disposal of shares by using a trust that was ...
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Sabina Margulies (Lexis®PSL Tax) reviews lessons from the Court of Appeal judgment.
The Court of Appeal decision in Haworth [2019] EWCA Civ 747 is a rarity in that the taxpayer was successful in challenging the validity of the follower notice (FN) and the accelerated payment notice (APN) based on it. Both notices were quashed.
In its decision the Court of Appeal provides useful guidance on interpreting FA 2014 s 205(3)(b) which is one of the conditions required for a judicial ruling to be ‘relevant’ to another taxpayer’s tax arrangements for the purpose of issuing an FN to that taxpayer.
What was the background?
Mr Haworth entered into a set of arrangements known as a ‘round the world’ tax scheme in 2000/01 under which he sought to avoid UK capital gains tax arising on the disposal of shares by using a trust that was ...
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:
