The ‘contrived and abnormal’ scheme was used by DH Limited, which was run by a sole director, whose identity was withheld in the ruling, and he was known only as AA.

The company was incorporated in 2007 and has been trading as a building business since then. AA was shareholder and sole director of the company and AB, the director’s wife, was only appointed as a director in 2019, after the events that are the subject of this GAAR opinion.

Y Limited was tax adviser to the company for most of the period under consideration in relation to the arrangements. The events in this case mainly took place in 2016 and 2017.