Inland Revenue Commissioners v Willoughby [1997] UKHL TC_70_57 (10 July 1997)
Income Tax – Avoidance – Transfer of assets abroad – Investments in offshore funds – Investments made both before and after taxpayers became resident in UK – Later investments subject to a specific tax regime – Whether anti-avoidance provision applied to transfers of assets made by transferor not resident in the UK – Whether exemption applied because avoiding tax not the purpose or one of the purposes of the transfer of assets – Income and Corporation Taxes Act 1988, ss 553, 739, 741-743.
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