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Avoidance schemes
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Avoidance schemes
AVOIDANCE-SCHEMES
M Murphy and another v HMRC
FTT finds that sub-sale avoidance scheme failed.
HMRC v Altrad Services Ltd and another
CA overturns UT decision in ‘magic’ capital allowances avoidance scheme.
S Clipperton and another v HMRC
Court of Appeal confirms that dividend replacement scheme failed.
Other cases that caught our eye: 26 January 2024
BADR and trusts:Trustees of the Peter Buckley Settlement v HMRC [2024] UKFTT 29 (TC) (4 January 2024) emphasises an important point about business asset disposal relief and trusts. A trust can obtain relief on a disposal of a qualifying asset (in...
Other cases that caught our eye: 28 July 2023
Petroleum revenue tax (PRT) and subsidiary argumentIn HMRC v Perenco UK Ltd [2023] UKUT 169 (TCC) (19 July 2023), the UT dismissed HMRC's appeal against the FTT decision. Consequently, expenditure incurred by the taxpayer during the relevant period...
Bhaur: mistake cannot unwind artificial avoidance scheme
Michael Avient
The Court of Appeal judgment in
Bhaur
provides a salutary lesson to those considering artificial tax avoidance schemes, writes Michael Avient (Temple Tax Chambers).
The smoke and mirrors of tax avoidance
Tom Wallace
It is important to look at any tax planning arrangement in the round and not simply the marketing material, Tom Wallace (WTT Consulting) explains.
Purpose and logic: Dunsby as a very modern tax case
Oliver Marre
Oliver Marre (5 Stone Buildings) examines a recent Upper Tribunal decision that demonstrates a modern approach to both the dividend taxing provisions and the settlement provisions found in ITTOIA 2005.
Ingenious Film Partners in the Court of Appeal: lights, camera, action!
Heather Self
Hannah Hurley
Heather Self and Hannah Hurley (Blick Rothenberg) examine the key points and the broader implications of the recent Court of Appeal decision.
Private client review for January 2021
Edward Reed
Claire Tilbrook
Edward Reed and Claire Tilbrook (Macfarlanes) provide this month’s private client update.
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EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
Read all
New HMRC manual on Mandatory Registration of Tax Advisers
New Advance Tax Certainty Manual
HMRC relax ERS reporting for short-term business visitors
HMRC update SP 1/2001
VAT Notice 742A clarification
CASES
Read all
Bagshaw Ltd v Revenue Scotland
HMRC v Healthspan Ltd
Other cases that caught our eye: 5 June 2026
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
IN BRIEF
Read all
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
MOST READ
Read all
TP adjustments and VAT: lessons from Stellantis Portugal
HMRC clarify CIS financing positions
Consultation tracker
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Ask an expert: Dividend planning under the new close company reporting regime