Dunsby v HMRC [2022] WTLR 81
Spring 2022 #186Mr Mark Dunsby participated in a tax avoidance scheme devised and promoted by De Sales Promotions Ltd. As part of the scheme, in March 2013, Mr Dunsby had a company, of which he was sole shareholder and director, issue a non-voting share to a non-resident individual, Mrs Fiona Gower. Mrs Gower established a trust and settled the share in the trust, with the benefit of any dividends being for Mr Dunsby, and Mr Dunsby’s company paid £200,000 as a dividend in respect of the settled share. As a result of the scheme, Mr Dunsby received £195,400. HMRC issued a closure notice dated 31 March 201...