Legal News

Tax planning involving loan notes

Published on: 09 March 2016
Published by: LexisPSL
  • Tax planning involving loan notes
  • Original news
  • What were the facts of this case?
  • What did the Upper Tribunal decide and why did it disagree with the FTT?
  • Although HMRC’s express ‘Ramsay’ argument failed, do you think its successful argument on statutory construction could be viewed as an application of a Ramsay ‘construed purposively, viewed realistically’ approach?
  • Was this type of planning common in the marketplace?
  • What does the decision tell us about the latest judicial thinking on tax avoidance and what may happen in the future?

Article summary

Tax analysis: How did the Upper Tribunal approach a capital gains tax planning scheme involving the rules on qualifying corporate bonds (QCBs)? Pete Miller, of the Miller Partnership, considers the decision in Hancock and another v Revenue and Customs Commissioners or take a trial to read the full analysis.

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