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In 2005/06 and 2006/07 the three taxpayers entered into a Tenon-promoted tax avoidance scheme that in essence created artificial losses by means of the purchase and surrender of an existing life assurance policy.
On their self assessment returns the taxpayers claimed the losses against capital gains. In the white space of the returns they included sufficient details of the insurance policy transactions.
The returns also indicated that the taxpayers had taken part in a scheme that had required prior disclosure to HMRC under the disclosure of tax avoidance schemes rules. The scheme was subsequently found to be ineffective.
The Revenue failed to open enquiries into the taxpayers’ returns in the specified period so the department instead made discovery assessments in respect of the gains.
The taxpayers appealed.
The First-tier Tribunal delivered a...
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