Interesting taxpayer win tax avoidance FTT case

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s 137 TCGA1992 has more or less the same "arrangements" wording as s306 FA 2004, which suggests that when considering DoTAS you look at the sale or whatever the commercial deal is and not just the tax advantage steps when considering the DoTAS main purpose test.

So you could say the planning was not caught by DoTAS for essentially the same reason it was not caught by s137 (presumably GT considered it was OK re DoTAS). That makes sense as GT could have been sued for not recommending this tax avoidance planning, as it clearly worked.



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