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Following on from Charlton, NIGEL EASTAWAY has his own experience to relate
KEY POINTS
- Use of a second-hand insurance policy scheme is declared in ‘white space’.
- HMRC say they need to be aware tax treatment adopted was contrary to their view.
- ‘Reasonable expectation’ and the Corbally-Stourton case.
- Internal review and reference to HMRC v Lansdowne Partners.
- Revenue backs down in face of arguments.
The recent article Rediscovering America by Aman Bharti gave an insider’s view on the case of Charlton & Ors v Revenue and Customs [2011] UKFIT 467 as he was one of the team that instructed counsel for the taxpayer.
The case concerned a discovery assessment following a second-hand insurance policy (SHIP) tax avoidance scheme ...
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