The Weekly Law Reports
[2022] 1 WLR 651
Court of Appeal
*Fisher and others
v
Revenue and Customs Commissioners
[2021] EWCA Civ 1438
2021 July 6, 7, 8; Oct 6
Newey, Arnold, Phillips LJJ
Revenue— Tax avoidance— Transfer of assets abroad— Taxpayers shareholders in UK company— Company transferring its betting business to Gibraltar company— Bets placed outside UK with Gibraltar company not subject to UK betting duty— Whether taxpayers liable to income tax on profits of Gibraltar company— Whether taxpayers liable as quasi-transferors of business— Whether actual avoidance of income tax necessary for liability to arise— Whether taxpayers having motive defence— Whether legislation incompatible with right to freedom of establishment—
Income and Corporation Taxes Act 1988 (c 1), ss 739, 741
—
FEU Treaty
, art 49
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