James Kessler QC and Amanda Hardy (instructed by Stephanie Churchill of Grant Thornton, Birmingham) for the taxpayers.
Tax avoidance – Transfer of assets abroad – Income payable to persons resident or domiciled outside the United Kingdom – Taxpayers becoming absolutely entitled to interest in significant income-producing real properties in UK at age of 18 – On eighteenth birthday taxpayers immediately transferring their interest to Jersey companies – Whether taxpayers able to demonstrate that transfers made without UK tax avoidance being one of their purposes – Whether transfer a bona fide commercial transaction and not designed for purpose of avoiding liability to tax – Income and Corporation Taxes Act 1988, ss 739, 741(1)(a), (b).