£11.3m PwC scheme ruled illegitimate
Upper Court rules against PwC client Howard Schofield
AN £11.3m options-based tax avoidance scheme devised by PwC was deemed illegitimate by the Upper Tribunal.
The scheme allowed the client, Howard Schofield, to accrue a loss of £11.3m which could be offset against a £10.7m capital gains tax liability, Citywire has reported.
The first tier tribunal ruled that the scheme, devised by the Big Four firm and Kleinwort Benson Private Bank, was tax avoidance with an “illusory aura of commerciality”.
“Viewing the scheme at this high level, Mr Schofield suffered no real commercial loss. On that approach, HM Revenue & Customs should succeed in defeating Mr Schofield’s claim to the allowable loss which he originally included in his self-assessment,’ Mr Justice Warren said in his judgement.