- 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?
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
Sign in or take a trial to read the full analysis.
To continue reading this news article, as well as thousands of others like it, sign in to LexisPSL or register for a free trial