The body reported this afternoon that The Court of Appeal ruled that NT Advisors’ latest scheme “consists of a series of circular payments designed purely to generate tax deductions with no genuine commercial purpose”.
No tax relief is therefore due, it said.
The latest ruling covers 304 users and will protect £143 million for the UK.
HMRC said in a statement: “This complex scheme devised by NT Advisors used a series of circular and self-cancelling transactions involving alleged overseas securities. These purported to create substantial tax deductions where in reality no economic loss had been suffered.”
The £916 million that HMRC said had been protected is from:
• ‘Chappell’, covering 304 users, protecting £143 million.
• ‘SG Repo’, ‘Working Wheels’ and ‘Stony Heating’, involving just over 1,000 users, protecting £630 million.
• A first-tier tribunal ruling against ‘Blue box’ involving 70 users and £48 million. NT Advisors are continuing litigation.
• ‘Romangate’ covering 359 users, protecting £95 million.
Previous HMRC victories against the firm included the defeat of the controversial Working Wheels scheme, where participants claimed to be second-hand car dealers.
In addition to the ten litigation wins, HMRC also successfully defended a Judicial Review brought by NT Advisors, which challenged the issue of Schedule 36 notices to obtain information on avoidance schemes.
HMRC said has collected £3 billion from users of tax avoidance schemes in the last two years under its “accelerated payments” programme, which collects disputed tax up front. It is also consulting on tough new penalties for accountants, tax planners and advisers who provide advice on how to avoid tax.
Jennie Granger, HMRC’s director general of enforcement and compliance, said: “HMRC has a 100% success record against NT Advisors in the courts. If you are currently using one of their schemes, or any other avoidance scheme, we will help you get out if you get in touch with us.”
HMRC’s dedicated helpline for people who have engaged in tax avoidance is 03000 530 435.