Market leading insight for tax experts
View online issue

Lancashire and others v HMRC

In Lancashire and others v HMRC [2020] UKFTT 407 (TC) (13 October 2020) the FTT considered a complex marketed scheme intended to enable the appellants to receive the majority of the income generated by the provision of their services to UK clients without attracting income tax and NICs.

Under the scheme each appellant established an Isle of Man settlement the trustee of which became a member of a partnership with the trustees of similar settlements. The partnership then entered into a services agreement with each appellant under which they agreed to provide services to UK third parties in return for a modest fee payable by the partnership. Each appellant also received as life tenant of their settlement their trustee’s share of the profits of the partnership. The appellants accepted that the fees were taxable as self-employed income in the UK but they contended that...

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.