HMRC v White Collar Financial Ltd

In HMRC v White Collar Financial Ltd [2020] UKFTT 459 (TC) (16 March 2020) the First-tier Tribunal (FTT) granted HMRC’s application for an order that arrangements were notifiable under the DOTAS rules (FA 2003 s 306) and that the company (WCF Ltd) was the promoter of them.

Under the arrangements individual participants became partners in a partnership which supplied their services as ‘consultants’ via an Isle of Man company to third parties. Each participant received amounts from the partnership in the form of drawings and from the Isle of Man company in the form of a loan. The loans represented up to 85% of the total receipts from the third party and participants were told by WCF Ltd that the loans would never have to be repaid. The loans were not declared in the participants’ tax returns.

The director of WCF Ltd indicated in a witness...

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