The Court of Appeal was satisfied that the First-tier Tribunal made no error of law in its approach when finding that the place of effective management of family trusts engaged in ‘round the world’ tax planning arrangements was the UK in the relevant period. 

The first and second appellants were the settlors of separate family trusts with trustees resident in Jersey, which engaged in a tax planning arrangement known as the ‘round the world’ scheme. The appellants hoped the trustees of the family trusts would avoid capital gains tax (CGT) on disposals of shares on the flotation of a company. The scheme would have been effective in achieving the CGT savings if (among other things) the family trusts became resident in Mauritius by the time of disposal and UK resident trustees were appointed in the same tax year. The arrangements required the place of effective management (POEM) of the trusts to have been in Mauritius. On appeal against