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The ‘tiger’ that (largely) failed to roar!

By Kevin Read, September 2020

Kevin Read reviews a recent case dealing with three distinct areas of tax. 

The owner of Hull City FC, who is perhaps best known for his unsuccessful attempts to change the club’s name to Hull Tigers FC, has recently been the appellant in Assem Allam v Revenue and Customs [2020] UKFTT 0026 (TC).  

That case involved three different issues, namely entrepreneurs’ relief (ER), the ‘transactions in securities’ (TIS) anti-avoidance rules (FA 2010, Sch 12) and business investment relief (BIR) (ITA 2007,s 809VA), the latter of which allows non-UK domiciled remittance basis users to remit income or gains to the UK without it being regarded as a taxable remittance.  

Allam Marine Ltd (AML), an engineering company, was owned by Allamhouse Ltd, a company owned by Dr and Mrs Allam.&nbsp

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