Boutique tax firm NT Advisors, described by the Revenue as a serial avoidance promoter, has lost its third appeal over a £100m tax scheme.
The scheme, branded Project Corbiere and devised by Matthew Jenner, involved transferring millions of pounds of government bonds, known as gilts, backwards and forwards to the British Virgin Islands to manufacture an unwarranted tax deduction of £1.2m.
The Court of Appeal judgement in Nicholas Barnes v Revenue and Customs  EWCA Civ 31 said the scheme exploited the fact that tax legislation offers two separate reliefs in some circumstances where securities are transferred.
“The first relief is an ‘accrued interest’ relief, and the second is a ‘manufactured interest’ relief. They deal with somewhat...