The Court of Appeal has unanimously rejected an appeal by a taxpayer against HMRC regarding a tax avoidance scheme recommended by PricewaterhouseCoopers in the early noughties.
The Court also refused permission for Howard Peter Schofield to appeal to the Supreme Court. The scheme, called Digital Collar, had been described by HMRC as "an artificial, circular, self-cancelling scheme designed with no purpose other than to avoid tax". In 2002, Schofield sold shares in his company, PL Schofield Limited, and made a considerable profit. Allowing for taper relief of 75%, he would have been liable to pay a tax bill of £10.7m for the 2002/3 tax year. However, after receiving advice from PricewaterhouseCoopers in 2003, he entered into the Digital Collar scheme in...
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