AVOIDANCE-SCHEMES

Film tax relief: In C Hoyle and others v HMRC [2024] UKFTT 1060 (TC) (26 November), the taxpayers took part in film tax schemes under which they invested in LLPs which leased film rights. Their investments were largely funded by loans and the...

FTT finds that sub-sale avoidance scheme failed.

CA overturns UT decision in ‘magic’ capital allowances avoidance scheme.

Court of Appeal confirms that dividend replacement scheme failed.

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...

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...

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).

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.

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.

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.

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