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17 August 2015
Issue: 4514 / Categories: Tax cases , Avoidance
C Fulbrook as agent for AEI Group Ltd and AEI Group Ltd (TC4483)
AEI was incorporated in the Bahamas and registered for VAT in the UK. In 2010 the taxpayer told HMRC that the company had been renamed AEI Group. It later transpired that the AEI Group was located in Belize and was a different company from AEI. The taxpayer who was agent for both companies said AEI had ceased in 2010 and its business was carried on by AEI Group from the date it was incorporated – 4 January 2010.
In 2012 HMRC issued notices to file tax returns for the periods ended 31 January 2007 to 31 January 2012 to AEI Group to the Bahamas address. Later HMRC became concerned that the company might not have been resident in the UK but instead might have been trading in the UK through a permanent establishment. They opened a corporation tax...

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