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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.
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