The ruling in favour of HMRC in respect of the application of retrospective taxation per BN66 applies only to the tax avoidance scheme that made use of limited partnerships and the double taxation treaty between the Isle of Man and UK. The way is now clear for HMRC to pursue contractors who made use of that scheme for retrospective taxation. It is likely however (but as yet cannot be confirmed) that a case will now be taken before the European Court of Human Rights where the ruling may or may not be overturned. There is no precedent in the European Court in such a case and so the outcome cannot be determined. It is the case however that there is a clear contravention in human rights where law or legislation is changed or implemented after the fact, as in this case.
We do not make use of double taxation treaty arrangements, we do not and have not ever operated such a scheme.
Our arrangement is founded in the basics of English common law, this type of arrangement continues to be used by many high net worth individuals, in addition to the many contractors who are also able to use it.