Andrew Goldstone and Moustapha Hammoud (Mishcon de Reya) provide a monthly update.
Fisher: shareholders and/or directors not ‘quasi-transferors’ under TOAA code
In S Fisher v HMRC [2020] UKUT 62 (TCC) the appellant taxpayers and their son (together T) successfully appealed against the FTT’s decision that the avoidance code on transfer of assets abroad (the ‘TOAA code’) applied to them in their capacity as shareholders and/or directors in a company.
The appellants were shareholders and/or directors of a UK betting business that was run through a UK resident company (SJA). The business consisted of betting shops in the UK and providing telephone and online betting services. Until 2001 general betting duty was charged on bets ‘made’ with a bookmaker in the UK.
In March 1999 SJA’s direct UK competitor Victor Chandler decided to...
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:
Andrew Goldstone and Moustapha Hammoud (Mishcon de Reya) provide a monthly update.
Fisher: shareholders and/or directors not ‘quasi-transferors’ under TOAA code
In S Fisher v HMRC [2020] UKUT 62 (TCC) the appellant taxpayers and their son (together T) successfully appealed against the FTT’s decision that the avoidance code on transfer of assets abroad (the ‘TOAA code’) applied to them in their capacity as shareholders and/or directors in a company.
The appellants were shareholders and/or directors of a UK betting business that was run through a UK resident company (SJA). The business consisted of betting shops in the UK and providing telephone and online betting services. Until 2001 general betting duty was charged on bets ‘made’ with a bookmaker in the UK.
In March 1999 SJA’s direct UK competitor Victor Chandler decided to...
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:
