The decision looks right to me. See para 141:
https://www.bailii.org/uk/cases/UKUT/TCC/2020/12.html
HMRC will be most pleased. Para 149 is helpful though re potential taxpayer carelessness. Also some interesting inconclusive remarks in para 155 re scheme promoter potential carelessness.
Also helpful is para 195 et seq. re Veltema disclosure.
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Yes this is a very interesting case.
It has important lessons for Accountants that prepare tax returns for cleints who use tax schemes the accountant or cleint doesn't understand.
I will be writing about it in depth next week.