Income Tax; emoluments; money’s worth; transfer of shares; readily convertible asset; Ramsay approach; tax avoidance scheme; Employee Benefit Trust; Discounted Options Scheme for employees in financial services industry; establishment of employee benefit trust; offshore companies established; money box company; family trust established; grant of option by offshore company in favour of family trust; transfer of shares to employee; value of shares; whether existence of family trust diluted value of shares transferred; Income and Corporation Taxes Act 1988 sections 1 19, 131, 202AandB, 203F The Income Tax (Employments) Regulations 1993 Regulation 2; (Pay As You Earn) Regulations 2003 Regulation 80, National Insurance; Social Security Contributions (Transfer of Functions) Act 1999 section 8;
Citations:
[2010] UKFTT 524 (TC)
Links:
Jurisdiction:
England and Wales
Cited by:
At FTTTx – Aberdeen Asset Management Plc v HMRC UTTC 9-Dec-2011
UTTC Income Tax; emoluments; tax avoidance scheme; transfer of shares; whether a payment -No; whether shares a readily convertible asset – Yes; Income and Corporation Taxes Act 1988 sections 1, 19, 131, 202AandB, . .
At FTTTx – Aberdeen Asset Management Plc v HM Revenue and Customs SCS 23-Oct-2013
Inner House – The Court analysed the nature of the rights which a tax avoidance scheme, involving an offshore employee benefits trust and family benefit trusts and shares in Isle of Man companies, had conferred on the relevant employees. The . .
Lists of cited by and citing cases may be incomplete.
Income Tax
Updated: 18 August 2022; Ref: scu.426604