Judy Harrison Senior Associate and Chris Bates Partner of Norton Rose LLP discuss two recent anti-avoidance cases Astall and Edwards v HMRC and Mayes v HMRC
There have been two recent cases which have considered whether it is possible to ignore steps inserted into transactions solely to obtain a tax advantage. Both of these cases involved high earners who wished to create a loss for tax purposes. In one case (Astall and Edwards v HMRC [2009] EWCA 1010) the court felt able to regard certain steps as being commercially irrelevant. In the other case (Mayes v HMRC[2009] EWHC 2443 (Ch)) the court did not feel able to disregard two steps even though they might be thought to have cancelled the economic effect of...
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Judy Harrison Senior Associate and Chris Bates Partner of Norton Rose LLP discuss two recent anti-avoidance cases Astall and Edwards v HMRC and Mayes v HMRC
There have been two recent cases which have considered whether it is possible to ignore steps inserted into transactions solely to obtain a tax advantage. Both of these cases involved high earners who wished to create a loss for tax purposes. In one case (Astall and Edwards v HMRC [2009] EWCA 1010) the court felt able to regard certain steps as being commercially irrelevant. In the other case (Mayes v HMRC[2009] EWHC 2443 (Ch)) the court did not feel able to disregard two steps even though they might be thought to have cancelled the economic effect of...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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