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‘Users of NT Advisors schemes or those considering using their schemes should know by now that HMRC is very successful at defeating them and give serious thought to ending their involvement.’

The financial secretary to the Treasury David Gauke comments on HMRC’s victory at the Upper Tribunal in Andrew Chappell v HMRC [2014] UKUT 0344 (TCC) . The subject of that case was the taxation of complex financial arrangements involving alleged overseas securities. HMRC says the ruling is expected to protect £156m in tax.

‘There are already streamlined procedures for recovery of tax due in UK courts. We are concerned that the direct recovery of debt from bank accounts without judicial supervision may not comply with data protection or human rights legislation. It would effectively reintroduce Crown preference – a measure swept away with good...

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