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N Andrew v HMRC

In N Andrew v HMRC [2019] UKFTT 177 (5 March 2019) the FTT found that Mr Andrew had suffered a relievable loss for the purpose of FA 1996 Sch 13 para 14A but that the amount claimed had to be reduced to reflect all the monies paid by the bank.

Mr Andrew had implemented a tax avoidance scheme known as the ‘AmberBox Income Tax Shelter Arrangements’ and marketed by BDO. The scheme entailed five steps: the creation of a trust for the benefit of Mr Andrew and his family; the acquisition of gilt strips by Mr Andrew; the grant by Mr Andrew to the trust of a call option over the gilts; the sale of the gilt strips subject to the call option by Mr Andrew to a third party bank; and the cancellation of the call option in consideration for a payment by the bank to the trustees.


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