Article summary
Tax analysis: In Development Securities, the Upper Tribunal (UT) overturned the decision of the First-tier Tax Tribunal (FTT) since it was incorrect as a matter of law. On the basis of the facts found by the FTT, the UT remade the decision, finding in favour of the taxpayers that the Jersey incorporated subsidiary companies (J subs) of a UK tax resident parent company were not centrally managed and controlled (and therefore not tax resident) in the UK even though the J subs’ directors acted in accordance with the instructions of the UK parent to enter into overvalued transactions in accordance with a scheme to avoid UK tax.
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