In the case of Schofield v HM Revenue & Customs [2012] EWCA Civ 927, HMRC has successfully challenged a multimillion pound tax avoidance scheme promoted by PwC. Howard Schofield incurred capital gains tax (CGT) liability in respect of £10,726,438 in gains accruing to him on the redemption of loan notes issued to him as consideration for his disposal of shares in P L Schofield Ltd.
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