Attention my UK Tax for International Clients students...

Quick message for all my CLT International STEP – Advising Families Across Generations 'UK Tax For International Clients students'... check out The Upper Tax Tribunal's decision in Davies v HMRC (2020 UKUT 67 TCC) where you will find a great discussion of the 'motive defence' we talked about in our last session together. The case shows that HMRC doesn't have to prove an allegation of tax avoidance, it is the taxpayer who must themselves prove there was no intention for avoidance.

Link to case here