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A fragile state: Part 2
Key points
- In Rangers Marlborough and Strategic Branding the courts have thus far not been consistent in deciding whether loans were taxable as earnings and whether the expenditure was deductible in computing CT.
- The weight which each court put on different facts in reaching judgment.
- The challenges of tax planning to get to a ‘fiscal paradise’ in a fragile system.
Epluribus unum or ‘one from many’ became the de facto motto of the newly independent USA reflecting the determination to form one nation from what had been disparate states. Both tax planners and HMRC often approach case law with a similar aim albeit from a different direction – extrapolating from one case where a scheme has been litigated (one decided in favour of or against the appellant as appropriate) to argue that the result applies to the many other taxpayers who have used the same...
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