AVOIDANCE-SCHEMES

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...

Oliver Marre (5 Stone Buildings) examines a recent Upper Tribunal decision that demonstrates a modern approach to both the dividend taxing provisions and the settlement provisions found in ITTOIA 2005.