- The sharp sting of tax avoidance—[R (De Silva) v HMRC]
- Original news
- What was the background to the case?
- What issues arose for the court’s consideration?
- What did the court decide, and why?
- To what extent is the judgment helpful in clarifying the law in this area? Are there still any unresolved issues practitioners will need to watch out for?
- How does the decision fit in with other developments in this area of law?
- What are the implications for practitioners?
Tax analysis: Whether HMRC had followed the correct procedure for enquiring into claims for income tax relief was the key to whether tax avoidance schemes using film partnerships succeeded or failed. Alison Foster QC, of 39 Essex Chambers, and Aparna Nathan, of Devereux Chambers, examine the Supreme Court's decision in R (De Silva) v HMRC.
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