Market leading insight for tax experts
View online issue

Clipperton revisited: open questions

Speed read
The Court of Appeal has found for HMRC on a Ramsay basis in its judgment in Clipperton v HMRC. In doing so, it distinguished the decision in Khan on the taxation of dividends from UK-resident companies and held that the ITTOIA settlements legislation purposively construed can apply widely. It leaves open questions around the need for the settlor to have provided an element of bounty and the risk of double taxation. After the announcements in the recent Budget, the decision repays close reading.

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.