Ramsay applied to deny loss arising under gilt strips scheme
In T Watts v HMRC [2022] UKFTT 408 (TC) (7 November 2022) the First-tier Tribunal (FTT) decided in favour of HMRC denying a taxpayer a substantial tax loss which purportedly arose in connection with a disposal of gilt strips under a tax avoidance scheme.
The gilt strips scheme broadly involved the following steps:
the acquisition of gilt strips with a value of circa £1.5m by the taxpayer using borrowed funds;
the grant of an option to buy the gilt strips to an interest in possession (IIP) trust of which the taxpayer was the settlor and life tenant for a premium of circa £1.3m with an exercise price of circa £150 000;
the assignment of the option in respect of the gilt strips to a bank (Investec) for a payment to the trustee of the IIP...
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Ramsay applied to deny loss arising under gilt strips scheme
In T Watts v HMRC [2022] UKFTT 408 (TC) (7 November 2022) the First-tier Tribunal (FTT) decided in favour of HMRC denying a taxpayer a substantial tax loss which purportedly arose in connection with a disposal of gilt strips under a tax avoidance scheme.
The gilt strips scheme broadly involved the following steps:
the acquisition of gilt strips with a value of circa £1.5m by the taxpayer using borrowed funds;
the grant of an option to buy the gilt strips to an interest in possession (IIP) trust of which the taxpayer was the settlor and life tenant for a premium of circa £1.3m with an exercise price of circa £150 000;
the assignment of the option in respect of the gilt strips to a bank (Investec) for a payment to the trustee of the IIP...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
