Fisher and Transfer of Assets Abroad
The Court of Appeal judgement in the long-running Fisher case (Fisher and Others v HMRC [2021] EWCA Civ 1438) arrived on 6 October. The case concerns a betting business transferred to Gibraltar, and the anti-avoidance legislation now in s720 ITA 2007. In a ruling which may surprise many, but encourage HMRC, the income of the trading company in Gibraltar was held to be taxab...
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