INCOME TAX� UK contractor with offshore employer providing services to UK end-users remunerated through EBT arrangements – whether FTT had jurisdiction to consider whether taxpayer entitled to PAYE credits under Regulations 185 and 188 of PAYE Regulations for sums end-users liable to deduct under PAYE – no. Whether FTT erred in finding discovery assessments valid – no. Transfer of Assets Abroad code -whether FTT erred in finding motive defence did not apply – non – whether FTT erred in finding income of’ person abroad’ was nil � no. Whether TOAA infringed taxpayer’s EU law free movement of capital – no. Taxpayer’s appeal dismissed, HMRC’s cross-appeal allowed in part.
[2021] UKUT 82 (TCC)
Bailii
England and Wales
Citing:
Appeal from – Hoey v Revenue and Customs (Procedure : Income Tax – IT Contractor Employed By Offshore Company) FTTTx 29-Jul-2019
INCOME TAX – IT contractor employed by offshore company – loans made to taxpayer from employee benefits trust set up by employer – whether or not payments by employer to EBT were taxable earnings – accepted by appellant – whether or not HMRC . .
These lists may be incomplete.
Updated: 20 June 2021; Ref: scu.662816