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...
Revell v HMRC [2016] UKFTT 97 (TC)
Summer 2017 #168On 10 December 2014, HMRC purported to close an enquiry into the appellant’s self-assessment for the year 2008/2009 by making amendments to the return so as to increase the tax due for that year to £16,518.60. The appellant appealed this decision principally on the basis that HMRC had failed properly to serve on him a request to file a self-assessment return.
HMRC had carried out a reconciliation of the appellant’s PAYE records showing a significant underpayment. HMRC sent a self-assessment return to what it thought was the appellant’s last known address. He did ...
Wood v HMRC [2016] UKUT 346 (TCC)
October 2016 #163In June 2010, Michael Wood admitted to under-declarations of income tax for the years 2002-03 to 2007-08 amounting to £743,424 and made a payment of tax of £352,983. This was made with a view to taking advantage of an HMRC disclosure opportunity for medical professionals called the ‘Tax Health Plan’, with a fixed tax geared penalty of 10% of the amount of tax under-declared. HMRC argued that the disclosure fell within the Tax Health Plan and opened a Code of Practice 9 investigation into his affairs. Michael Wood agreed to provide a disclosure report (the disclosure report) into his affa...