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United Kingdom Upper Tribunal (Tax and Chancery Chamber)
You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> Chappell v Revenue & Customs [2014] UKUT 344 (TCC) (28 July 2014)
URL: http://www.bailii.org/uk/cases/UKUT/TCC/2014/344.html
Cite as: [2015] STC 271, [2014] STI 2581, [2014] UKUT 344 (TCC), [2014] BTC 523

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Chappell v Revenue & Customs [2014] UKUT 344 (TCC) (28 July 2014)


INCOME TAX – tax avoidance scheme – whether there was transfer of overseas securities and payment of manufactured overseas dividend when relevant statutory provisions construed purposively and transactions viewed realistically - no – whether annual payment not payable under deduction and retention of income tax was deductible for purposes of income tax - no – if payment deductible as payment of manufactured overseas dividends treated as annual payments within section 349(1) ICTA 1988 whether Section 3 ICTA 1988 restricts tax relief to higher rate – yes – appeal by Appellant dismissed and appeal by Respondents allowed

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URL: http://www.bailii.org/uk/cases/UKUT/TCC/2014/344.html