A complicated tax avoidance scheme involving the sale of shares in Anglia Water Group from Scottish to Irish trusts and then to a large investment bank did not work, a tribunal has ruled.
In an appeal to the first tier tribunal (TC05025) the trustees for the three trusts and Sir Fraser Morrison argued that gains on the sale of Scottish Trust shareholdings in AWG (by setting up of five Irish trusts, the exercise of “put options”, the purchase and sale of the shareholdings by the Irish trusts, the replacement of these trustees with the original trustees under the Scottish trusts and the consequent repatriation of these trusts) should have no or minimal capital gains tax.
HMRC argued that under the “Ramsay” principle, the transactions, which ended with a sale of...
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