Commentary

V7.190 Disaggregation—cases won by HMRC

Part V7 Tax planning
Part V7 Tax planning | Commentary

V7.190 Disaggregation—cases won by HMRC

Part V7 Tax planning | Commentary

V7.190 Disaggregation—cases won by HMRC

HMRC were successful in the three cases summarised below.

  1.  

    •     Smith t/a Ty Gwyn Hotel v Customs and Excise Comrs ([2001] Lexis Citation 913) (MAN/01/0065 17406) – in this particular case, Mrs Smith ran the catering part of the business, but the only payment she made to her husband towards the facilities she enjoyed was to provide free sandwiches to pub customers on a Thursday night. It was argued by the Smiths that this was her way of paying for the kitchen and equipment facilities she enjoyed within the premises.

  2.  

    However, the reality of the

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