The application of Ramsay in a recent case and HMRC’s revised guidance on salaried members are among the topics covered in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
Vaccine Research Limited Partnership: application of Ramsay
It is unusual in a tax avoidance case for a taxpayer to rely on Ramsay and win but that is what happened in The Vaccine Research Limited Partnership and another v HMRC [2025] UKFTT 402 TC (TVRLP). The fundamental issue before the First-tier Tribunal (FTT) was whether licence fees receivable by a partnership as part of a circular tax-driven funding arrangement were ‘income’. If they were income the next question was whether the income was taxable under ITTOIA...
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The application of Ramsay in a recent case and HMRC’s revised guidance on salaried members are among the topics covered in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
Vaccine Research Limited Partnership: application of Ramsay
It is unusual in a tax avoidance case for a taxpayer to rely on Ramsay and win but that is what happened in The Vaccine Research Limited Partnership and another v HMRC [2025] UKFTT 402 TC (TVRLP). The fundamental issue before the First-tier Tribunal (FTT) was whether licence fees receivable by a partnership as part of a circular tax-driven funding arrangement were ‘income’. If they were income the next question was whether the income was taxable under ITTOIA...
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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