Key points
- The challenges of disguised remuneration planning given the principle of fragility.
- The different decisions in Rangers Marlborough and Strategic Branding.
- Why the court decided the Strategic Branding planning did not achieve its ends.
All happy families are alike; each unhappy family is unhappy in its own way. So begins Anna Karenina Tolstoy’s epic novel of family and tragedy in imperial Russia.
The idea that happy families share a fairly consistent set of attributes while the attributes which lead to an unhappy family are practically limitless has gained wide traction. It was developed by the mathematician Vladimir Arnold in his principle of fragility – a good system must meet a number of requirements simultaneously which means that good systems are inherently fragile. Sadly there is no such restriction on bad systems and so these are more likely. Which brings us to tax planning in...