Alan Newman Q.C. and James Kessler for Allen.
Income tax—Transfer of assets abroad—Transfers to foreign companies—Whether imposition of tax liability on UK residents had effect of excluding tax liabilities of foreign companies—Whether such exclusion to be implied—Income and Corporation Taxes Act 1988, ss 739(2) and 743(1)—Human Rights Act 1998 Part II, Art 1.
Income tax—Shadow directors—Whether shadow directors liable to tax under Sch E in respect of benefits in kind and accommodation—Income and Corporation Taxes Act 1988, ss 19, 145, 154, 167 and 168.