- Ocean Finance—the jury is still out
- Original news
- What is the issue?
- What did the CJEU decide?
- Do the court’s comments on how the transaction should be ‘re-established’ constitute a departure?
- Does it enhance our understanding of the Halifax principle?
- What should lawyers advising in this area take note of?
- Is there a trend emerging in this area?
Tax analysis: Did loan broker Ocean Finance set up and use ‘wholly artificial’ arrangements with the sole aim of obtaining a tax advantage in relation to its advertising costs? Sadiya Choudhury, barrister at Pump Court Tax Chambers discusses the CJEU’s decision in Newey t/a as Ocean Finance v Revenue and Customs Commissioners.
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