Goldfinger Gold Bullion Tax Avoidance Scheme – Goldfinger Corporate Tax
What Is Happening Now?
FS Litigation’s specialist tax litigation team is advising individuals affected by the Goldfinger Gold Bullion Tax Avoidance Scheme — also known as Goldfinger Corporate Tax — following HMRC’s aggressive enforcement and successful application of the General Anti-Abuse Rule (GAAR).
We have been instructed in claims against both scheme promoters, such as Achilles Products Ltd and Redbox Tax Associates LLP, and the professional advisers who introduced clients to these arrangements without properly warning them of the risks.
In some cases, investors now face liabilities running into seven figures as a result of HMRC assessments.
How the Scheme Worked
The Goldfinger Scheme was designed to enable directors, shareholders or senior employees of SMEs to extract remuneration while avoiding Corporation Tax, Income Tax, PAYE and National Insurance Contributions.
The structure of the scheme was extremely complex. It involved the purchase of a second-hand insurance bond from an Isle of Man entity, an 'out of the money' gilt option with one bank, a substantial loan from another bank, and the notional creation of a capital sum in gold bullion.
At the conclusion of this multi-step process, the directors or shareholders would supposedly receive company profits tax-free, with no exposure to Corporation Tax or CGT.
HMRC’s Response
HMRC reacted decisively, raising assessments in respect of unpaid tax and NICs. They also successfully challenged the scheme under the General Anti-Abuse Rule (GAAR), which was introduced specifically to counteract aggressive tax avoidance strategies.
In one example, FS Litigation acted on behalf of a client with a liability well into seven figures. That case was pursued under a no-win, no-fee agreement and successfully resolved via mediation.
Wider Legal Risks
Participants in the Goldfinger Scheme may face substantial tax bills and penalties. Legal redress may be available against accountants, tax advisers or other professionals who failed to warn of the scheme’s risks or failed to carry out adequate due diligence.
FS Litigation is working alongside specialist tax and professional negligence counsel to bring claims against such advisers and their insurers.
FS Litigation’s Expertise
FS Litigation is one of the UK’s few law firms specialising in claims arising from failed tax schemes and negligent professional advice. We have successfully pursued claims against accountants, tax advisers and scheme promotors — including Achilles Products Ltd — in connection with schemes like Goldfinger.
We are ranked Band 1 by Chambers & Partners and recognised by The Legal 500 for our work in high-value tax-related disputes.
Chambers & Partners: “The team is especially skilled acting on high-value tax-related disputes.”
Legal 500: “FS Litigation has a national reputation for high-profile, multi-million pound ‘big ticket’ litigation... its team is the envy of many of the top law firms it comes up against.”
Commenting on the scheme, George Rowell of Exchange Chambers said:
“The Goldfinger Scheme was a blatant attempt to frustrate Parliament’s intention that the owners and managers of a business should pay tax on the money they extract for their personal benefit. It was always entirely predictable that HMRC would attack the Scheme with all the legal weapons at their disposal. From July 2013 those weapons included the General Anti-Abuse Rule, which was specifically designed to defeat aggressive tax avoidance schemes such as this one.”
What Should You Do?
If you participated in the Goldfinger Scheme or suspect your adviser introduced it, early legal advice is essential. Strict time limits may apply.
We offer a free, confidential consultation and act under no-win, no-fee arrangements in the majority of our claims.
Funding Options
FS Litigation offers a range of funding solutions and acts on a contingent (‘no-win, no-fee’) basis in most professional negligence claims.
We also work with external tax advisers and litigation funders to support clients in managing HMRC exposure and resolving liabilities.
Contact Us
To speak confidentially with a member of our team, please contact us or call us on 0161 714 4520