Legal News

Tax weekly highlights—14 January 2021

Published on: 14 January 2021
Published by: LexisPSL
  • Tax weekly highlights—14 January 2021
  • In this issue:
  • Anti-avoidance
  • FTT applies Ramsay to defeat loss creation scheme (Padfield v HMRC)
  • Finance
  • CIOT responds to proposed Finance Bill 2021 amendments to the hybrid and other mismatch rules
  • Taxes management and litigation
  • Partial closure notice must state tax due (HMRC v Embiricos)
  • CIOT responds to consultation on reforms to obtaining permission to appeal to the Court of Appeal
  • International
  • More...

Article summary

This week’s edition of Tax highlights includes: (1) the FTT’s decision in Padfield that arrangements entered into by the taxpayers fell ‘fairly and squarely’ within the Ramsay principle and therefore did not create the losses that they were designed to achieve, (2) the UT’s decision in Embiricos that HMRC could not issue a partial closure notice denying the taxpayer’s claim to the remittance basis without specifying the amount of tax due, (3) the UT’s decision in Rialas that there was no income tax charge under the transfer of assets abroad rules where the taxpayer had made arrangements to facilitate the sale of shares by his business partner to a non-resident company owned by a trust of which he was beneficiary, and (4) changes to the SDLT return for the non-resident surcharge of 2%. or take a trial to read the full analysis.

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