FOREIGN COMPANY – motive test – captive insurance – whether main purpose of transaction with the captives was to obtain tax reduction – no – whether main reason for the existence of the captives was to achieve a reduction of tax by diversion of profits from the UK – yes -Taxes Act 1988 s.748(3).
Citations:
[2002] UKSC SPC00359
Links:
Statutes:
Income and Corporation Taxes Act 1988 74893)
Citing:
Cited – Mallalieu v Drummond HL 27-Jul-1983
The taxpayer was a barrister. To comply with Bar guidance on court dress, she wore, in court and in and to and from chambers black dresses, suits and shoes and white blouses. The clothing were perfectly ordinary articles suitable for everyday wear. . .
Lists of cited by and citing cases may be incomplete.
Income Tax
Updated: 10 June 2022; Ref: scu.195409
