Decision Number: | TC 08477 |
Appellant: | THE COMMISSIONERS FOR HER MAJESTY'S REVENUE AND CUSTOMS |
Respondent: | (1) SMARTPAY LIMITED (incorporated in the UK) (2) SMARTPAY LIMITED (incorporated in the Isle of Man) |
Chairmen / Special Commissioners: |
Asif MALEK |
Date Of Decision: | 03/05/2022 |
Main Category: | PROCEDURE |
Main Subcategory: | Other |
Notes: | Disclosure of tax avoidance schemes - Whether the arrangements were notifiable arrangements - Whether the Respondents were promoters - Finance Act 2004 ss 306, 307- The Tax Avoidance Schemes (Prescribed Descriptions of Arrangements) Regulations 2006, SI 2006/1543 reg 8 - HMRC v Curzon Capital Ltd [2019] UKFTT 63 & HMRC v Hyrax Resourcing Ltd & Ors [2019] UKFTT 175 considered. |