Mike Lane and Zoe Andrews (Slaughter and May) review recent developments affecting the City.
Unallowable purpose rule applies to disallow all debits
The Court of Appeal in Travel Document Service and another v HMRC [2018] EWCA Civ 549 unanimously dismissed the appeals of Travel Document Services (TDS) and Ladbroke Group International (LGI). The case concerns a tax avoidance scheme notified under DOTAS. The transactions took place in 2008 the essence of which were to exploit a perceived loophole in the FA 1996 loan relationships rules as they were at the time. The scheme involved TDS bringing a holding of LGI’s shares within the loan relationships rules by entering into a total return swap (the Swap) in relation to them then depressing the value of the shares by novating a large loan liability into LGI from another group company. On the basis of the...
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Mike Lane and Zoe Andrews (Slaughter and May) review recent developments affecting the City.
Unallowable purpose rule applies to disallow all debits
The Court of Appeal in Travel Document Service and another v HMRC [2018] EWCA Civ 549 unanimously dismissed the appeals of Travel Document Services (TDS) and Ladbroke Group International (LGI). The case concerns a tax avoidance scheme notified under DOTAS. The transactions took place in 2008 the essence of which were to exploit a perceived loophole in the FA 1996 loan relationships rules as they were at the time. The scheme involved TDS bringing a holding of LGI’s shares within the loan relationships rules by entering into a total return swap (the Swap) in relation to them then depressing the value of the shares by novating a large loan liability into LGI from another group company. On the basis of the...
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:
