Chancery Division.

Judgment delivered 8 October 1986.

Income tax – Tax avoidance – Transfer of assets abroad – Income derived from services of taxpayer payable to overseas company – Taxpayer entering into employment with Jersey company – Company’s only trade consisted of taxpayer’s activities in UK – Whether company’s income deemed to be that of taxpayer – Whether sale by taxpayer of income derived from his personal activities – Whether taxpayer had power to enjoy income of non-UK resident – Income and Corporation Taxes Act 1970, sec. 478, 487.

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