HM Revenue and Customs (HMRC) are well known for their robust attitude towards tax avoidance schemes they consider to be questionable and, over the years, have introduced an ever-increasing variety of rules and regulations in combating such schemes and taken court proceedings over a number of them, with varying degrees of success.

HMRC have recently issued guidance on such schemes, called 'Ten things a promoter of tax avoidance schemes won't always tell you', and though the guidance is clearly intended to act as a disincentive to those considering such schemes, it does contain some useful material.

It is important when considering any tax planning exercise to ensure that the proposals are legal and will be able to withstand a potential challenge.