It is encouraging to see the FTT dealing robustly with situations where HMRC fail to discharge their burden of proof, writes Sophie Rhind (Macfarlanes).
Neil Fletcher (Alvarez & Marsal) discusses the implications of the decision for taxpayers where this is an obvious commercial purpose and a tax advantage.
In a letter to the Treasury Committee, Jim Harra, HMRC Chief Executive and First Permanent Secretary, has defended HMRC’s approach to the loan charge and disguised remuneration (DR) tax avoidance schemes more generally. In his conclusions, Harra put...