The Resource Lee and another v Revenue and Customs Commissioners : [2017] UKFTT 279 (TC)

Lee and another v Revenue and Customs Commissioners : [2017] UKFTT 279 (TC)

Label
Lee and another v Revenue and Customs Commissioners : [2017] UKFTT 279 (TC)
Title
Lee and another v Revenue and Customs Commissioners : [2017] UKFTT 279 (TC)
Creator
Contributor
Subject
Language
eng
Summary
Judgment by the First-Tier Tribunal, Tax Chamber, judgment date 7 April 2017. This case is related to the efficacy of a tax avoidance scheme also known as Round-the-World scheme. Under the scheme, assets held within an UK offshore trust became loaded with gain and were migrated to a low-tax jurisdiction (Mauritius), with which the UK has a tax treaty. The gain was realised but not taxed. The trust was subsequently transferred to the UK where the proceeds of sale were free of UK tax. HMRC argued that they were liable to UK capital gains tax on the gains. The taxpayers appealed. The appeals were dismissed. The First-tier Tribunal stated that the identification of the place of effective management (POEM) of the settlements in the scheme was in that case of fundamental importance
Citation source
In: International tax law reports. - London. - Vol. 19 (2017), part 5; p. 741-783
http://bibfra.me/vocab/relation/comm
wgxhYUYtE4w
http://library.link/vocab/creatorName
Avery Jones, J.F
Geographic coverage
  • European Union
  • Europe
  • Africa
Language note
English
http://library.link/vocab/relatedWorkOrContributorName
Baker, P
http://library.link/vocab/subjectName
  • place of effective management
  • tax evasion
  • case law
  • trust
  • capital gains
  • tax treaty
Label
Lee and another v Revenue and Customs Commissioners : [2017] UKFTT 279 (TC)
Instantiates
Publication
Label
Lee and another v Revenue and Customs Commissioners : [2017] UKFTT 279 (TC)
Publication

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