The taxpayers entered into a tax avoidance scheme devised by a firm of accountants to shelter over £1 million of taxable income. In brief they became settlors of a life interest trust and lent money to the trust in return for a security issued by one of the trustees a company. The taxpayers had three options:
- redeem the security;
- sell the security to a third party and redeem it at 5% of the redemption price on seven days notice; or
- hold the security for 15 years.
The taxpayers took the second option selling the security to a third party bank for a substantial loss which redeemed the security at 5% of the principal amount. The taxpayers then claimed the difference between the issue price and 6% of the issue price as a loss on a relevant...
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.