Jonathan Crowther on how the results of a court case held 24 years ago are still affecting tax planning strategies and HM Revenue & Customs' approach
In the early 1970s the UK's punitive levels of taxation lead to the development of tax planning schemes, which set in motion a series of transactions that helped save tax without affecting the economic position of the taxpayer. Firstly, there was a scheme or plan to avoid the payment of tax otherwise payable. Secondly, the scheme included artificial steps for which there was no commercial justification. Thirdly, if each artificial step was considered in isolation, the tax liability had been expunged, but if the scheme was regarded as a whole, the liability had only been disguised. The R...
To continue reading this article...
Join Professional Adviser for free
- Unlimited access to real-time news, industry insights and market intelligence
- Stay ahead of the curve with spotlights on emerging trends and technologies
- Receive breaking news stories straight to your inbox in the daily newsletters
- Make smart business decisions with the latest developments in regulation, investing retirement and protection
- Members-only access to the editor’s weekly Friday commentary
- Be the first to hear about our events and awards programmes