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Tax avoidance motive can affect nature of transactions (Clavis Liberty 1 LP v HMRC)

Tax avoidance motive can affect nature of transactions (Clavis Liberty 1 LP v HMRC)
Published on: 25 April 2016
Published by: LexisPSL
  • Tax avoidance motive can affect nature of transactions (Clavis Liberty 1 LP v HMRC)
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Article summary

Tax analysis: The First-tier Tax Tribunal (FTT) has dismissed the taxpayer’s appeal in respect of a claim for a trading loss that arose as part of a tax avoidance scheme. The FTT gave consideration to the application of the Ramsay doctrine and the question of whether the existence of a tax avoidance motive can convert what is, on all other measures, a trade into something that is not a trade. or take a trial to read the full analysis.

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