|
Decision Number: |
TC 05028 |
|
Appellant:
|
Clavis Liberty 1LP(acting through Mr D J Cowen) |
|
Respondent:
|
The Commissioners for Her Majesty's Revenue & Customs |
Chairmen / Special
Commissioners: |
John L WALTERS QC
|
|
Date Of Decision:
|
18/04/2016 |
|
Main Category:
|
INCOME TAX/CORPORATION TAX |
|
Main Subcategory:
|
Anti-avoidance |
|
Notes:
|
INCOME TAX – tax avoidance scheme – Partnership purchasing rights to dividends and receiving dividends – whether dividends are excluded from the computation of income of the Partnership for tax purposes giving rise to a loss – section 730 ICTA 1988 – held no – whether Partnership trading in short-dated securities – held yes – whether the purchase of dividend rights and receipt of dividends were transactions in the course of that trade – held no – whether certain fees in respect of tax advice were a deductible trading expense – held no – appeal dismissed |
|
Decision(s) to Download:
|
TC05028.pdf 
|
