In Peter and Jaleh Hearn t/a Hennerton Golf Club v HMRC [2014] UKFTT 1115 (29 December 2014) the FTT found that arrangements were abusive under the Halifax principle.
Mr and Mrs Hearn ran a golf club in partnership. With effect from 1 February 1998 the business of the club was split into two main activities: a licence of the land by the partnership to the company (the golf course); and the supply of services by the company to the members of the club. The result was that both activities were treated as exempt by the taxpayers.
The issue was whether the reorganisation of the business had constituted an abusive practice under the Halifax principle (Halifax Plc and others v HMCE (C-255/02) [2006] STC 919). Looking at the arrangements as a whole and assessing their aim objectively the FTT asked itself whether they were contrary to...
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In Peter and Jaleh Hearn t/a Hennerton Golf Club v HMRC [2014] UKFTT 1115 (29 December 2014) the FTT found that arrangements were abusive under the Halifax principle.
Mr and Mrs Hearn ran a golf club in partnership. With effect from 1 February 1998 the business of the club was split into two main activities: a licence of the land by the partnership to the company (the golf course); and the supply of services by the company to the members of the club. The result was that both activities were treated as exempt by the taxpayers.
The issue was whether the reorganisation of the business had constituted an abusive practice under the Halifax principle (Halifax Plc and others v HMCE (C-255/02) [2006] STC 919). Looking at the arrangements as a whole and assessing their aim objectively the FTT asked itself whether they were contrary to...
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