In R Grint v HMRC [2024] UKFTT 956 (TC) (25 November) the FTT found that the sale of occupation income avoidance rules applied to a capital sum arising on incorporation. Though there were commercial reasons for incorporation reduction of tax was still a main motive and the anti-avoidance provisions were engaged despite an error in HMRC’s £1.8m closure notice assessment.
In 2011 ten years after filming started for the first Harry Potter film Clay 10 Ltd was formed to supply Mr Grint’s acting services. Mr Grint was sole shareholder; his father and manager sole director. Existing and future rights together with business information and goodwill in respect of the actor were transferred to the company for consideration of £8.5m.
The consideration was left outstanding as a shareholder loan account with £4.5m treated...
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In R Grint v HMRC [2024] UKFTT 956 (TC) (25 November) the FTT found that the sale of occupation income avoidance rules applied to a capital sum arising on incorporation. Though there were commercial reasons for incorporation reduction of tax was still a main motive and the anti-avoidance provisions were engaged despite an error in HMRC’s £1.8m closure notice assessment.
In 2011 ten years after filming started for the first Harry Potter film Clay 10 Ltd was formed to supply Mr Grint’s acting services. Mr Grint was sole shareholder; his father and manager sole director. Existing and future rights together with business information and goodwill in respect of the actor were transferred to the company for consideration of £8.5m.
The consideration was left outstanding as a shareholder loan account with £4.5m treated...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
