The Resource Mark Higgins Rallying (a firm) v Revenue and Customs Commissioners : [2011] UKFTT 340 (TC)

Mark Higgins Rallying (a firm) v Revenue and Customs Commissioners : [2011] UKFTT 340 (TC)

Label
Mark Higgins Rallying (a firm) v Revenue and Customs Commissioners : [2011] UKFTT 340 (TC)
Title
Mark Higgins Rallying (a firm) v Revenue and Customs Commissioners : [2011] UKFTT 340 (TC)
Creator
Contributor
Subject
Language
eng
Summary
Judgment by the First-Tier Tribunal (Tax Chamber) dated 20 May 2011. Mark Higgins was a motor rally driver who was discovered by Mr Dixon, a former rally driver and now a successful investor and businessman. Both were resident in the Isle of Man. Mr Dixon prepared a partnership agreement by which he would promote Mr Higgins in both the UK and overseas rallying. Mr Higgins' family moved to Wales to set up a rallying school and he went with them. Mr Dixon prepared a memorandum on how the partnership was to be managed in order to prevent it becoming subject to UK tax law. In particular, all partnership meetings were held in the Isle of Man and all the promotion contracts were signed there except for one which was signed in the UK when the matter was urgent. HMRC investigated the partnership and considered that in view of the fact that Mr Higgins conducted most of the activities for which the partnership made him available in the UK. This raised the issue that the management of the partnership might not be entirely outside the UK, in which case it would be susceptible to taxation in the UK. Finding the partnership to be controlled in the Isle of Man, the Tribunal held that a partnership resided where its high-level decisions were made
Citation source
In: International tax law reports. - London. - Vol. 13 (2011),
http://bibfra.me/vocab/relation/comm
wgxhYUYtE4w
http://library.link/vocab/creatorName
Avery Jones, J.F
Geographic coverage
Europe
Language note
English
http://library.link/vocab/relatedWorkOrContributorName
Baker, P
http://library.link/vocab/subjectName
  • case law
  • residence
  • partnership
  • central management and control
Label
Mark Higgins Rallying (a firm) v Revenue and Customs Commissioners : [2011] UKFTT 340 (TC)
Instantiates
Publication
Label
Mark Higgins Rallying (a firm) v Revenue and Customs Commissioners : [2011] UKFTT 340 (TC)
Publication

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