Taxpayer achieves Income Tax loss in High Court Case: EWHC 2443 (2009) Mayes v HMRC

October 10th 2009

The High Court have found in favour of the taxpayer in a tax avoidance scheme known as ‘Ships 2′, in the case of Mayes v HM Revenue & Customs.

The primary objective of the scheme was to use corresponding deficiency relief to reduce the liability to higher rate income tax for UK resident individuals.  The scheme involved a part-surrender of certain single premium “non-qualifying” life assurance policies, followed by a full surrender by the individual investor who could then claim the relief.

The Court allowed the appeal on behalf of the taxpayer, enabling the loss to be claimed.