Mark Higgins Rallying (a firm) v Revenue and Customs Commissioners : [2011] UKFTT 340 (TC)
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The work Mark Higgins Rallying (a firm) v Revenue and Customs Commissioners : [2011] UKFTT 340 (TC) represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.
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Mark Higgins Rallying (a firm) v Revenue and Customs Commissioners : [2011] UKFTT 340 (TC)
Resource Information
The work Mark Higgins Rallying (a firm) v Revenue and Customs Commissioners : [2011] UKFTT 340 (TC) represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.
- Label
- Mark Higgins Rallying (a firm) v Revenue and Customs Commissioners : [2011] UKFTT 340 (TC)
- 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
- Geographic coverage
- Europe
- Language note
- English
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/resource/vIW-SDiYgMw/" typeof="CreativeWork http://bibfra.me/vocab/lite/Work"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/resource/vIW-SDiYgMw/">Mark Higgins Rallying (a firm) v Revenue and Customs Commissioners : [2011] UKFTT 340 (TC)</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="http://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
