http://financeandtax.decisions.tribunals.gov.uk/judgmentfiles/j10988/TC0...
And a rare appearance from RVQC.
A good decision, except re para 173. As far as I am aware, there is no such "artificial" definition/requirement in the legislation or case law re Ramsay, DoTAS or otherwise (on the contrary, as recently stated in the case in the link below "tax avoidance is the spur to executing genuine documents and entering into genuine arrangements").
https://www.accountingweb.co.uk/any-answers/interesting-rare-case-of-tax...
HMRC were lucky they did not end up losing on an admin. slip-up as in the case in the link below:
https://www.accountingweb.co.uk/any-answers/very-embarrassing-dotas-case-defeat-for-hmrc
The point about witnesses staying silent is dealt with at p189 here also:
http://financeandtax.decisions.tribunals.gov.uk/judgmentfiles/j10989/TC0...
I doubt it helped much that they were all sat in the room with the judge!
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Justin it might help if you said who you think would find that interesting - or to whom it might apply - or something to save others trawling through a sizeable document for (in my case; I would venture I am not alone) no gain.
Thank you.
[I applaud the decision though. Absolutely right.]