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06 October 2008
Categories: Tax cases
ZXCV Ltd and others (SpC 706)

A chartered accountant who had previously been a vet set up 500 companies which he intended to sell off the shelf to Australian locum vets who worked in the UK. His wife was the sole shareholder and director of each company with the taxpayer being the secretary. Bank accounts were set up for 26 of the companies but applications for the remainder were refused because of money laundering concerns.

None of the companies traded. For each company the 'cash in' columns of the petty cash sheets contained an entry of £1 as 'cash received'. The 'cash out' column had 78p entered as 'director's remuneration' and 22p as 'IR-PAYE'. A form P35 was submitted online for each company for the tax year 2004-05 and the taxpayer applied for incentive payments of £250 for each company as a small employer.

HMRC made 33 incentive payments.

The taxpayer did...

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