Revenue and Customs Commissioners v Curzon Capital Ltd

Income tax – Tax avoidance scheme. The capital contracts arrangements that the taxpayer company was involved in were 'notifiable' arrangements within the meaning of s 306 of the Finance Act 2004. However, the taxpayer's activities did not fall within s 307(1)(a)(ii) or (iii) and accordingly, it was not a promoter of those arrangements within s 307(1)(b) of that Act. Consequently, the First-tier Tribunal (Tax Chamber) dismissed the Revenue and Customs Commissioners' application for an order, pursuant to s 314A of the Act, that those arrangements were 'notifiable' arrangements.

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