Peter Vaines on the return of the Ramsay doctrine in Shofield v HMRC
For those like me who thought that the Ramsay doctrine had disappeared into the long grass as a result of the House of Lords decisions in Westmoreland and Barclays Mercantile the case of Schofield v HMRC [2010] UKFTT 196 TC00498 came as a surprise.
Schofield was a loss scheme in which various things happened with some gilt options and up popped a loss — and a very similar profit. The profit was of course not taxable (otherwise it would obviously have been a waste of time) but the loss was designed to be allowable against gains made by the taxpayer on other transactions. I apologise for this rather flippant summary which does not do justice to the intellectual ingenuity of the arrangements but they are mercifully explained in detail elsewhere.
HMRC denied relief for...
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Home >Articles > Schofield v HMRC: Is Ramsay back from the wilderness?
Schofield v HMRC: Is Ramsay back from the wilderness?
Peter Vaines on the return of the Ramsay doctrine in Shofield v HMRC
For those like me who thought that the Ramsay doctrine had disappeared into the long grass as a result of the House of Lords decisions in Westmoreland and Barclays Mercantile the case of Schofield v HMRC [2010] UKFTT 196 TC00498 came as a surprise.
Schofield was a loss scheme in which various things happened with some gilt options and up popped a loss — and a very similar profit. The profit was of course not taxable (otherwise it would obviously have been a waste of time) but the loss was designed to be allowable against gains made by the taxpayer on other transactions. I apologise for this rather flippant summary which does not do justice to the intellectual ingenuity of the arrangements but they are mercifully explained in detail elsewhere.
HMRC denied relief for...
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