Peter Fisher, Stephen Fisher, Anne Fisher and The Commissioners for HM Revenue and Customs: [2020] UKUT 0062 (TCC)
Upper Tribunal Tax and Chancery decision of Mrs Justice Andrews and Judge Poole on 4 March 2020.
Read the full decision in .
Income tax – anti-avoidance – transfer of assets abroad – s.739 ICTA88 – transfer of betting business by UK company to Gibraltar company – whether TOAA code applies to shareholders where no purpose of avoiding income tax – whether transfer can be imputed to shareholders as multiple quasi-transferors – whether all trading profit of transferee company assessable – whether motive defence available – whether TOAA code breached EU law – whether discovery validly made – appeal allowed.
Published 4 March 2020