According to HMRC, the ruling by Court of Appeal to uphold its decision had “saved the country £100m”. Prior to the Court of Appeal’s decision, the First-tier and Upper Tribunals had also agreed with HMRC’s decision.
HMRC said the “complex” scheme was devised by Matthew Jenner for a company called NT Advisors.
Branded Project Corbiere, it involved transferring millions of pounds of UK government bonds, known as gilts, backwards and forwards to the British Virgin Islands to manufacture an unwarranted tax deduction of £1.2m. The Court of Appeal said the scheme was specifically designed to avoid tax.
HMRC said some 230 wealthy individuals who first used the scheme in 2005 have already settled their tax bills with HMRC, but that around £80m “could have been lost to the UK” if this latest appeal had been successful.
Exchequer secretary to the Treasury David Gauke said: “This is an important win for HMRC and is the latest in a string of successes. It is excellent news for the vast majority of taxpayers who play by the rules.
“Many users of this scheme have already accepted the inevitable and settled up with HMRC and those who haven’t should do so quickly.
“This government has provided HMRC with nearly £1bn to clamp down on tax avoidance, evasion and fraud. We recently announced proposals which will give HMRC stronger powers to tackle promoters and users of avoidance schemes sending a clear signal that tax avoidance doesn’t pay.”