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Elizabeth Wilson KC

Elizabeth Wilson KC is a member of Pump Court Tax Chambers. She was lead counsel for HMRC in Kwik-Fit and JTI. She can be contacted through her clerks by email: clerks@pumptax.com.
ARTICLES

ELIZABETH WILSON, barrister, explains the limited scope of the 'associated operations' rule by reference to a popular scheme.

IT IS COMMONLY suggested that the gift with reservation of benefit 'associated operation' rules apply to the gift of the debt in the 'double trust' home loan plan. (For more detailed discussion on this, see article by Ian Maston in Taxation, 20 September 2001 at pages 621 to 623.) This article sets out why, in my opinion, there is no problem.

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