H A Patel and K Patel (a partnership) v HMRC [2014] UKFTT 167 (TC)

September 2014 #142

The appellants had established a remuneration trust by a trust deed dated 26 March 2010 and of which they were the protectors. As such, they had the power to appoint and remove trustees, including Bay Trust International Ltd (the trustee). On the day of its establishment, the appellants applied to the trustee for loans of £550,000 which were duly advanced the same day. They were also directors of GSA Investments Ltd, a UK company to which the trustee (via another company in Belize) delegated powers to invest the trust funds.

The respondent issued an information notice dated 14 Se...