UTTC Income Tax and NICs: scheme to deliver bonuses in form of shares avoiding income tax and NIC. S18(1) ITEPA Rule 2 – whether employee became ‘entitled to payment’ when amount of bonus determined. Ch 2 Part 7 ITEPA – whether shares were ‘estricted securities’ within s 423(2)(c) – s 429 whether shares were in … Continue reading UBS AG v HM Revenue and Customs: UTTC 17 Sep 2012
UBS AG devised an employee bonus scheme to take advantage of the provisions of Chapter 2 of the 2003 Act, with the sole purpose other than tax avoidance, and such consequential advantages as would flow from tax avoidance. Several pre-ordained steps were taken according to a detailed timetable. Once the structure of the scheme had … Continue reading UBS Ag and Another v Revenue and Customs: SC 9 Mar 2016
The two companies had established schemes designed to minimise tax on payments to employees, using a purpose made company to take advantage of exemptions under section 423. In oe cse the Revenue appealed against rejection of its challenge,nd in the other the taxpayer. Held: HMRC’s appeal failed, and that of the second company (UBS) succeeed. … Continue reading DB Group Services (UK) Ltd v Revenue and Customs: CA 16 Apr 2014
Regulation 80, PAYE Regulations – Section 8, Social Security Contributions (Transfer of Functions, etc) Act 1999 – whether sums paid into a share scheme were earnings of the staff for whom they were paid – whether the shares purchased as part of the scheme were restricted securities within the meaning of Chapter 2 of Part … Continue reading Deutsche Bank Group Services (UK) Ltd v Revenue and Customs: FTTTx 19 Jan 2011
FTTTX Income tax – Income Tax (Earnings and Pensions) Act 2003 (ITEPA) 2003 Part 3 – Earnings and benefits treated as earnings – whether Appellant could offset claimed but unproven credit balance on directors loan account – no – Appeal dismissed [2015] UKFTT 21 (TC) Bailii Income Tax (Earnings & Pensions) Act 2003 England and … Continue reading White v Revenue and Customs: FTTTx 19 Jan 2015
FTTTX Income tax – Income Tax (Earnings and Pensions) Act 2003 (ITEPA) 2003 Part 3 – Earnings and benefits treated as earnings – whether Appellant could offset claimed but unproven credit balance on directors loan account – no – Appeal dismissed [2015] UKFTT 22 (TC) Bailii Income Tax (Earnings & Pensions) Act 2003 England and … Continue reading Roberts v Revenue and Customs: FTTTx 19 Jan 2015