HMRC has won a further round of its long-running and complex litigation against the Icebreaker tax avoidance schemes. In Seven Individuals v HMRC [2017] UKUT 0132 (TC) the Upper Tribunal (Nugee J) dismissed the appeals of a number of individual members of the schemes against the first-instance decision of the First-tier Tribunal (Tax Chamber) which had prevented them from setting their individual shares of their LLP’s trading loses against other income for income tax purposes.

Nicholas Macklam acted for HMRC, led by Jonathan Davey KC. A copy of the decision can be found here.