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Hearing and evidence
Hearing and evidence
We had:
a 492-page hearing bundle containing HMRC’s statement of case (original and revised versions), other procedural documents relating to the appeal, two witness statements from Ms Tonkin, and other relevant documents and correspondence
a 93-page supplementary bundle containing accounts for the Company
a 266-page respondent’s authorities bundle, a 593-page appellant’s authorities bundle and a 22-page supplementary authorities bundle for the appellant, each of which contained relevant legislation and case law, and
both parties’ skeleton arguments, plus a supplementary skeleton argument for Ms Tonkin.
Ms Tonkin attended the hearing and gave oral evidence. Her two witness statements stood as her evidence in chief and she was cross-examined. We found her to be a reliable and credible witness.
- Heading
- Introduction
- Hearing and evidence
- Findings of fact
- The scheme transactions
- History of the tax dispute
- Relevant law
- Discussion
- The parties’ submissions on the meaning of profits or gains
- Our view on the meaning of profits or gains
- The parties’ submissions on who received the transfer of value
- Our view on who received the transfer of value
- Whether the transfer falls to be taken into account for the purposes of income tax
- Conclusions