Sara Luder of Slaughter and May discusses the recent HMRC consultation document on a principles-based approach to financial products avoidance
Sara Luder of Slaughter and May discusses the recent HMRC consultation document on a principles-based approach to financial products avoidance
'An assignment of income from property without an assignment of the underlying property will no matter what its form bring about the result that the consideration for that assignment will be on revenue account as being merely a substitution for the future income that is to be derived.'
The above is a statement of Hill J in an Australian case 1 which apparently HMRC thinks of as a 'useful statement of principle for an income tax system'. Unfortunately for HMRC the UK courts do not agree: The Court of Appeal in...
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Sara Luder of Slaughter and May discusses the recent HMRC consultation document on a principles-based approach to financial products avoidance
Sara Luder of Slaughter and May discusses the recent HMRC consultation document on a principles-based approach to financial products avoidance
'An assignment of income from property without an assignment of the underlying property will no matter what its form bring about the result that the consideration for that assignment will be on revenue account as being merely a substitution for the future income that is to be derived.'
The above is a statement of Hill J in an Australian case 1 which apparently HMRC thinks of as a 'useful statement of principle for an income tax system'. Unfortunately for HMRC the UK courts do not agree: The Court of Appeal in...
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:
