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The Treasury needs to take responsibility in tax policy, says PHILIP SHIRLEY
KEY POINTS
- The point of the accrued income scheme
- If an action is unusual does this make it artificial?
- Law enforcers are not necessarily good at devising law
Now that litigation in the D'Arcy case in which I advised Mrs D'Arcy has ended I can respond to Mike Truman who has taken a particular interest in this case see Claim of the rose and It's the clients.
HMRC decided not to appeal further from the High Court decision and have now closed the enquiries into other gilt repo transactions.
Since Mr Truman referred to the D'Arcy case as being iconic in his recent Hardman lecture I thought I would comment.
The scheme
The D'Arcy case concerned the short sale of gilts over a dividend payment date. Mrs D'Arcy entered into a sale and...
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