Peter Fisher, Stephen Fisher, Anne Fisher and The Commissioners for HM Revenue and Customs: [2020] UKUT 0062 (TCC)
Upper Tribunal Tax and Chancery decision of Mrs Justice Andrews and Judge Poole on 4 March 2020.
Read the full decision in .
Income tax 鈥� anti-avoidance 鈥� transfer of assets abroad 鈥� s.739 ICTA88 鈥� transfer of betting business by UK company to Gibraltar company 鈥� whether TOAA code applies to shareholders where no purpose of avoiding income tax 鈥� whether transfer can be imputed to shareholders as multiple quasi-transferors 鈥� whether all trading profit of transferee company assessable 鈥� whether motive defence available 鈥� whether TOAA code breached EU law 鈥� whether discovery validly made 鈥� appeal allowed.
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Published 4 March 2020