Clavis Liberty Fund 1 LP v The Commissioners for HM Revenue and Customs: [2017] UKUT 0418 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Mann on 19 October 2017.
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INCOME TAX – tax avoidance scheme – Partnership purchasing rights to dividends and receiving dividends – whether the purchase of dividend rights and receipt of dividends were transactions in the course of that trade – held no – whether certain fees in respect of tax advice were a deductible trading expense – held no – appeal dismissed.
Published 20 October 2017