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Court of Appeal’s decision in Bostan Khan

15 June 2021 / Nathan Ross-Sercombe
Issue: 4796 / Categories: Comment & Analysis
A bridge too far?

Key points

  • Transactions undertaken to wind down a company.
  • Who was the true beneficiary of the deal?
  • Court of Appeal’s view on the application of the Ramsay principle.
  • Importance of taking professional advice before embarking on a deal.
  • HMRC can instigate an enquiry many years after the transaction took place.

It was with great optimism on 20 April this year that my client Bostan Khan and I joined the remote Court of Appeal hearing regarding the personal tax impact on Mr Khan of his acquisition of Computer Aided Designers Ltd (CAD) from the three former shareholders.

It was also a familiar feeling in some ways. Mr Khan had first approached my former firm for specialist advice on HMRC’s investigation into the transaction. Having sat with Mr Khan during the First-tier Tribunal and Upper Tribunal hearings and having received decisions in respect of both it was with no less frustration...

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