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Eyretel Unapproved Pension Scheme and others v Revenue and Customs: SCIT 12 Nov 2008

SCIT CAPITAL GAINS TAX – tax avoidance scheme – whether subscription for shares followed by the return of the subscription money by way of dividend (by an unlimited company), followed by disposal of the shares for a nominal amount five months after the subscription was a self-cancelling composite transaction – yes – whether HMRC can … Continue reading Eyretel Unapproved Pension Scheme and others v Revenue and Customs: SCIT 12 Nov 2008

Jones v Garnett (Inspector of Taxes): ChD 28 Apr 2005

The taxpayer worked as an information technology specialist. His earnings were channelled through a limited company. The company paid on part of its income to his wife, with the result that the total tax paid was reduced. The inspector sought to tax the sum paid to the taxpayer’s wife as a settlement made on her … Continue reading Jones v Garnett (Inspector of Taxes): ChD 28 Apr 2005

Patmore v Revenue and Customs: FTTTx 14 Jul 2010

FTTTx DIRECT TAX – Husband and wife jointly fund share purchase – over 97% shares purchased transferred to husband- new class of shares allotted to wife – wife receives approximately 40% of dividends – whether settlement under s660A ICTA 88. Citations: [2010] UKFTT 334 (TC) Links: Bailii Statutes: Income and Corporation Taxes Act 1988 660A … Continue reading Patmore v Revenue and Customs: FTTTx 14 Jul 2010

Bird and Another v Revenue and Customs: SCIT 3 Nov 2008

SCIT INCOME TAX – Settlement – Company owned by husband and wife – Allotment of shares in company to their minor children on subscription at par – Payment of dividends to children – Whether settlement by virtue or in consequence of which dividends were paid within meaning of Income and Corporation Taxes Act 1988 ss. … Continue reading Bird and Another v Revenue and Customs: SCIT 3 Nov 2008

Rogge and Others v Revenue and Customs: FTTTx 12 Jan 2012

Income Tax – Settlor interested trust – Trust income consisting of payments made by settlor – Whether settlor is liable to tax on trust income by virtue of s 660A Income and Corporation Taxes Act 1988 – Yes Citations: [2012] UKFTT 49 (TC) Links: Bailii Jurisdiction: England and Wales Income Tax Updated: 03 September 2022; … Continue reading Rogge and Others v Revenue and Customs: FTTTx 12 Jan 2012