Corporate partners

We refer to the issue of corporate partners which makes regular appearances on the Readers Forum pages the latest of which was on 10 February 2011 (see replies to query 17 741 Corporate partners).

We feel there are a number of problems with the type of planning involved in this arrangement and that it is potentially caught by the anti-avoidance provisions in TA 1988 s 775.

This was raised briefly in the reply submitted by Ji Hao Zhang but we feel that the point should be made again.

The planning involves the sale of occupation income for a capital sum and therefore the amount received could be subject to income tax under Schedule D Case VI.

If the planning has been undertaken after 6 April...