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Offshore trusts: A taxing business
A successful taxpayer appeal against HMRC has lessons on how the courts will interpret legislation on the transfer of assets abroad. Remi Aiyela explains ‘Even though Mr Rialas orchestrated the purchase side of the transaction as HMRC claimed, it was stretching the meaning of the word “procure” beyond breaking point to suggest that the fact …
Cases Referenced
Cases in bold have further reading - click to view related articles.
- Burns v HMRC [2009] STC (SCD) 165
- Carvill v IRC [2000] STC (SCD) 143
- Inland Revenue Commissioners v Pratt [1982] STC 756
- Inland Revenue Commissioners v Willoughby [1997] UKHL 29
- Rialas v HMRC [2019] UKFTT 520 (TC); [2019] WTLR 1251 FTT (TC)
- Vestey v IRC [1979] UKHL TC/54/503
- X GmbH v Finanzamt Stuttgart – Körperschaften [2019] EUECJ C-135/17