Patrick Cannon Tax Barrister 15 Old Square considers the recent decision of the Special Commissioner in Drummond v Revenue and Customs Commissioners
The Special Commissioners have recently shown themselves willing to utilise a strong purposive approach and an 'unblinkered' analysis of the facts when presented with cases involving pre-ordained tax schemes. Cases such as EDI Services v HMRC (No 2) [2006] SCD 392 come to mind (EDI involved the payment of bonuses in gold coins in order to avoid NICs where the inserted steps were regarded as simply a mechanism to deliver (NICable) cash payments to recipients because of the near inevitability that the gold coins would be sold immediately for cash).
A further remarkable example of this approach has occurred in the recent decision of Sir...
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Patrick Cannon Tax Barrister 15 Old Square considers the recent decision of the Special Commissioner in Drummond v Revenue and Customs Commissioners
The Special Commissioners have recently shown themselves willing to utilise a strong purposive approach and an 'unblinkered' analysis of the facts when presented with cases involving pre-ordained tax schemes. Cases such as EDI Services v HMRC (No 2) [2006] SCD 392 come to mind (EDI involved the payment of bonuses in gold coins in order to avoid NICs where the inserted steps were regarded as simply a mechanism to deliver (NICable) cash payments to recipients because of the near inevitability that the gold coins would be sold immediately for cash).
A further remarkable example of this approach has occurred in the recent decision of Sir...
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:
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