Maya Forstater

(2) artificially low commission rate?

4 a thing 2b a tax risk factor there has 2b tax law by reference 2 which the tax might b understated

so in order to get a positive from my test you would need to have identified that relevant tax law

Section 416, Income Tax Act 2007 Condition A 'the gift takes the form of a sum of money'?

nearly there ... gift is structured 2b money, so you need a basis for looking behind the structure

4 it to work u hv to get the person who thinks they are donating a shoe, & the vol who thinks they are accepting donations...

...to play along with the fake commission deal....riskier than just saying 'thanks for donating the shoes, we will sell them'

maybe but u need 2 identify the law which you say that recharacterisation risk arises by reference 2 (Ramsay principle perhaps?)