HMRC has published a guidance note on FB 2014 (Part 5 and Schs 30–32), promoters of tax avoidance schemes. It contains a flowchart and examples. The guidance explains that the objectives of the regime are to:
Few advisers will be surprised at the First-tier Tribunal’s rejection of the highly artificial ‘blue box’ tax planning scheme. David Whiscombe examines the decision which provides a useful summary of the current position on the Ramsay principle
Nigel Doran analyses the 147 page tribunal decision, which has attracted so much recent media coverage.
BKL Tax reports on the case of Gardiner, involving tax avoidance and negligence
The scheme involved ‘gifting’ gilts to a charity subject to option and security arrangements which ensured that 99% of the gilts would be passed on to a trust set up for the benefit of Mr Ferguson and his family.
Income tax scheme failed
Icebreaker scheme fails
HMRC has published guidance on the new anti-avoidance measure introduced by Finance Bill 2014, which prevents non-trading finance profits of a CFC from being regarded as a qualifying loan relationship where an arrangement to transfer profits out of the UK exists.
Availability of partnership losses to individual partners