Andrew Davies and Others v The Commissioners for HM Revenue and Customs: [2020] UKUT 0067 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Morgan and Judge Andrew Scott on 10 March 2020.
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INCOME TAX – transfer of assets abroad – s 739 ICTA 1988, ss 720 and 721 ITA 2007 – exemption from these provisions – s 741 ICTA 1988, s 739 ITA 2007 – purposes of transactions– whether open to First-tier Tribunal to make findings, adverse to the Appellants, as to purposes – yes – whether Appellants entitled to rely on Article 7 of UK/Mauritius double tax treaty – no – whether (if they were) they were out of time to claim relief - yes.
Published 10 March 2020