Application

Associated companies

Avoidance of VAT

Bonuses in the form of contingent reversionary interests in offshore trusts

Case examples

Conclusions

Generally

Derivative transactions, chargeable gains allowable losses mitigation scheme

Evolution

BMBF case

Generally

Foreign exchange transactions

Composite transaction

Generally

Generally

Gilt strip planning, loss relief

Income of beneficiary trust

Inheritance tax

Business property relief, associated operations

Reverter to settlor scheme

Series of transactions

Inter-group transactions

Interest payments

Generally

Investment company

Payments in kind

Practice buy out scheme, restrictive covenant

Reconstruction of group of companies, transactions in securities

Repayment of surplus advance corporation tax

Reverse annuity schemes

Scope

Series of transactions

Generally

Pre-ordained, stamp duty

Single composite transaction of the disposal/redemption of non-QCBs

Stamp duty

Tax avoidance scheme, disposal of real estate

Transfer of assets abroad, income of beneficiary of trust