Heather Self (Pinsent Masons) considers a recent case about a complex financial transaction where HMRC prevailed on an ‘unallowable purpose’ argument.
the disclosure of tax avoidance scheme (DOTAS) rules in 2004 it was reported that the then Inland Revenue had met the big four accounting firms to complain about their role in selling a particular avoidance scheme (see ‘Big four warned about their role in ‘unacceptable’ tax avoidance’ Financial Times 17 March 2004). Despite this many of the recent cases that have reached the tribunal particularly in relation to schemes around financial instruments and loan relationships have emanated from the big four. The latest case Travel Document Service and Ladbroke Group International v HMRC [2015] UKFTT 582 (reported in Tax Journal...
