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HMRC wins rate-booster case

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HMRC has been quick to publicise its success in a tax case involving Next Brand Ltd, which is part of the Next group, over its use of a tax avoidance structure known as a rate-booster. The FTT ruled in HMRC’s favour after finding Next’s scheme artificially moved money around the group so they could try and claim tax relief on overseas profits and is now facing a £22.4m tax bill (see our case report on page 5).

HMRC’s director general of business tax, Jim Harra said: ‘This case shows how HMRC takes effective action against big businesses that try to avoid paying tax through convoluted, artificial avoidance schemes. HMRC expects all businesses to steer well clear of such schemes.’

This is the second rate-booster case to reach the FTT after the tribunal ruled against P&O in 2013, who have appealed and a decision is awaited. About £130m in tax is at stake across 20 rate-booster cases, which were waiting on the P&O and Next decisions. Around 70 rate-boosters have already been conceded by companies rather than go to court, which has brought in more than £500m in tax.