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The arrangements under consideration
The arrangements under consideration
Section 318 FA 2004 defines “arrangements” as including “any scheme, transaction or series of transactions”. It is apparently accepted by Moir that there was a series of transactions – and thus an arrangement – which took place in respect of each of their individual clients.
The arrangements under consideration here, described by HMRC as the “Jarvis International Annuity arrangement”, took the form set out below.
- Heading
- Introduction
- Burden of proof in these proceedings
- Procedural point
- Evidence before the FTT
- Additional background facts
- The arrangements under consideration
- Step one
- Step two
- Step three
- Step four
- Issue 1 - was Moir a “promoter” of “notifiable arrangements” as defined by sections 306 and 307 FA 2004 ?
- Issue 2 - if so, did Moir fail to comply with its obligations under sections 308 and 313A FA 2004 ?
- Issue 3 – if so, does Moir have a reasonable excuse for its non-compliance?
- Issue 4 - if not, what quantum of penalty is Moir liable to pay?
- Conclusions