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Padfield v HMRC

In S Padfield and others v HMRC [2020] UKFTT 513 (TC) (23 December 2020) the First-tier Tribunal (FTT) held that arrangements entered into by the taxpayers fell ‘fairly and squarely’ within the Ramsay principle and therefore did not create the losses that they were designed to achieve.

The taxpayers had entered into arrangements known as the ‘volatility investment strategy’ that were designed to produce (at each taxpayer’s choice) either capital losses or income losses. These were intended to be set against the taxpayers’ capital gains or certain categories of taxable income.

The scheme involved each taxpayer entering into ‘trades’ with a bank (Schroders). Under each trade the taxpayer entered into two forward contracts with the bank to be settled around a month later on the ‘valuation date’. The price was fixed but the nature of the securities passing under the contracts depended on the...

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