Clavis Liberty Fund 1 LP v The Commissioners for HM Revenue and Customs: [2017] UKUT 0418 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Mann on 19 October 2017.
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INCOME TAX 鈥� tax avoidance scheme 鈥� Partnership purchasing rights to dividends and receiving dividends 鈥� whether the purchase of dividend rights and receipt of dividends were transactions in the course of that trade 鈥� held no 鈥� whether certain fees in respect of tax advice were a deductible trading expense 鈥� held no 鈥� appeal dismissed.
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Published 20 October 2017