AVOIDANCE-SCHEMES

The recent cases of Bhaur and JTC illustrate the opportunities and challenges for taxpayers who have misunderstood the tax consequences of a transaction, write Ben Elliott and Arthur Wong (Pump Court Tax Chambers).

LLP not trading, so tax deductions and R&D relief denied.

Ramsay argument fails to save taxpayer from £10m tax assessment  

Insolvency consequences of a failed avoidance scheme: C Purkiss v T Kennedy and others [2025] EWCA Civ 268 (14 March) is not a tax case but will be of interest to many tax practitioners because it concerns the insolvency consequences of a failed...

Film tax relief: In C Hoyle and others v HMRC [2024] UKFTT 1060 (TC) (26 November), the taxpayers took part in film tax schemes under which they invested in LLPs which leased film rights. Their investments were largely funded by loans and the...

FTT finds that sub-sale avoidance scheme failed.

CA overturns UT decision in ‘magic’ capital allowances avoidance scheme.

Court of Appeal confirms that dividend replacement scheme failed.

BADR and trusts:Trustees of the Peter Buckley Settlement v HMRC [2024] UKFTT 29 (TC) (4 January 2024) emphasises an important point about business asset disposal relief and trusts. A trust can obtain relief on a disposal of a qualifying asset (in...

Petroleum revenue tax (PRT) and subsidiary argumentIn HMRC v Perenco UK Ltd [2023] UKUT 169 (TCC) (19 July 2023), the UT dismissed HMRC's appeal against the FTT decision. Consequently, expenditure incurred by the taxpayer during the relevant period...