[2015] UKFTT 0448 (TC)

[The appeal against this decision is reported at [2017] BTC 508.]

Judge Jonathan Cannan, Mr Alban Holden

Decision released 3 September 2015

Income tax – Tax avoidance scheme – Isle of Man double taxation arrangements – Application of Income Tax (Trading and Other Income) Act 2005 (‘ITTOIA 2005’), s. 858 – Whether appellant was entitled to the income of an Isle of Man partnership – Application to amend grounds of appeal to rely on further grounds – Appeal dismissed.

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