.png)
.png)
The taxpayer took part in a complicated avoidance scheme involving gilt strip transactions which allowed him to claim loss relief on a sum equivalent to the amount of a coupon payment on borrowed gilts.
He received interest of £1.2m and claimed the sum on his self-assessment return on the basis the accrued income rules in TA 1988 s 710 to s 728 relieved him of the tax liability.
In addition his payment of the manufactured interest payment to the custodian company gave rise to a loss of £1.2m under the manufactured interest rules in Sch 23A (now ITA 2007 s 578 and s 579 (manufactured dividends and interest)) which he aimed to set against his other income.
HMRC refused the claim; the First-tier Tribunal dismissed an appeal by the taxpayer on the basis he was not entitled to relief. The taxpayer appealed.
The Upper Tribunal...
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
