Murray Group Holdings and Others v Revenue and Customs: FTTTx 29 Oct 2012

FTTTx Income Tax and NIC – Schedule E – emoluments/earnings – tax avoidance scheme – Remuneration Trust – employees’ individual sub-trusts – ‘protectors’ – (1) whether payments by employer into trust represent emoluments subject to PAYE and NIC; – (2) whether benefits (particularly loans) derived by employees from the Remuneration Trust represent emoluments subject to PAYE and NIC; – (3) ‘Ramsay’ doctrine – whether applicable – whether trust and loan arrangements artificial and fall to be disregarded; – No – Appeal allowed.

Citations:

[2012] UKFTT 692 (TC), [2013] SFTD 149, [2013] STI 492

Links:

Bailii

Statutes:

Income and Corporation Taxes Act 1988

Jurisdiction:

Scotland

Cited by:

Appeal fromRevenue and Customs v Murray Group Holdings Ltd and Others UTTC 8-Jul-2014
UTTC Income Tax and NIC – emoluments/earnings – tax avoidance scheme – remuneration trust – employees’ individual sub-trusts – ‘protectors’ – (1) whether payments into sub-trusts were emoluments/earnings subject . .
At FTTTxThe Advocate General for Scotland v A Decision of The Upper Tribunal, Re Assessments To Tax Made On Murray Group Holdings Ltd and Others SCS 4-Nov-2015
Second Division Inner House) The AG appealed from a finding that a tax avoidance was not a sham. TH AG brought a new argument, that the payment of the sums to the remuneration trust involved a redirection of the employee’s earnings and accordingly . .
At FTTTxRFC 2012 Plc (Formerly The Rangers Football Club Plc) v Advocate General for Scotland SC 5-Jul-2017
The Court was asked whether an employee’s remuneration is taxable as his or her emoluments or earnings when it is paid to a third party in circumstances in which the employee had no prior entitlement to receive it himself or herself.
Held: The . .
Lists of cited by and citing cases may be incomplete.

Income Tax

Updated: 18 August 2022; Ref: scu.570119