Arrangements involving an umbrella company which operated a contractor loan scheme involving an Isle of Man company engaging with a partnership for the supply of consultants were notifiable arrangements for disclosure of tax avoidance scheme purposes.
Summary
Arrangements involving an umbrella company which operated a contractor loan scheme involving an Isle of Man company engaging with a partnership for the supply of consultants were notifiable arrangements for disclosure of tax avoidance scheme (DOTAS) purposes, within the meaning of FA 2004, s 306.
Background
The respondent was an umbrella company (‘WCF’), which operated a contractor loan scheme arrangement. Under the arrangement, an Isle of Man company (‘OT’) engaged with a partnership;(
