HMRC defeated as Jersey companies deemed not UK-resident

The UK's Upper Tribunal has decided that three special purpose vehicles (SPVs) incorporated in Jersey as part of a tax planning arrangement were not tax resident in the UK for tax purposes, overturning a  2017 decision from the First-tier Tax Tribunal. Development Securities, a property and investment group based in the UK, created the subsidiaries in Jersey to gain tax advantages.The group had assets standing at a loss and decided to enter into a scheme designed by PwC to increase the capital losses.  Under this scheme, the SPVs holding the assets would grant call options to the Jers...