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Harrison News Ltd v Revenue and Customs: FTTTx 15 Apr 2011

Appeal against Regulation 80 of the Income Tax (Pay As You Earn) Regulations 2003 determinations and Section 8 Social Contributions (Transfer of Functions) Act 1999 decisions-Appellant appealed on basis that HMRC had not provided an adequate breakdown of the amounts assessed appeal dismissed Citations: [2011] UKFTT 251 (TC) Links: Bailii Statutes: Income Tax (Pay As … Continue reading Harrison News Ltd v Revenue and Customs: FTTTx 15 Apr 2011

Sloane Robinson Investment Services Ltd v Revenue and Customs: FTTTx 16 Jul 2012

FTTTx Employees’ bonus payments – whether entitlement to cash or to shares – s 18 and 686 and Part 7 of ITEPA 2003 – s 42 of Companies Act 1985 – tax avoidance scheme – purposive interpretation of statutes – Ramsay and PA Holdings considered – appeal dismissed Judges: Malachy Cornwell-Kelly TJ Citations: [2012] UKFTT … Continue reading Sloane Robinson Investment Services Ltd v Revenue and Customs: FTTTx 16 Jul 2012

Ralc Consulting Ltd v Revenue and Customs (Income Tax – Pay As You Earn – National Insurance): FTTTx 29 Oct 2019

INCOME TAX – PAY AS YOU EARN – NATIONAL INSURANCE CONTRIBUTIONS – Intermediaries Legislation – IR35 – Personal Service Companies (PSC) – s.49 of the Income Tax (Pay As you Earn) Act 2003 (ITEPA) – Determinations under Regulation 80 of the ITEPA Regulations 2003 – Provision of IT consultancy services – notional or hypothetical contracts … Continue reading Ralc Consulting Ltd v Revenue and Customs (Income Tax – Pay As You Earn – National Insurance): FTTTx 29 Oct 2019

Slush Puppie Ltd v Revenue and Customs: FTTTx 25 May 2012

Contract of employment or contract for services – no written terms – notice under section 8 of the Social Security Contributions (Transfer of Functions etc) Act 1999 – determination under regulation 80 of the Income Tax (Pay As You Earn) Regulations 2003 – appeals allowed Citations: [2012] UKFTT 356 (TC) Links: Bailii Statutes: Social Security … Continue reading Slush Puppie Ltd v Revenue and Customs: FTTTx 25 May 2012

Aberdeen Asset Management Plc v Revenue and Customs: FTTTx 29 Oct 2010

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 … Continue reading Aberdeen Asset Management Plc v Revenue and Customs: FTTTx 29 Oct 2010

Exchequer Solutions Limited v Revenue and Customs: FTTTx 13 Jun 2022

PAYE and NIC – travel and subsistence expenses – whether ordinary commuting or travel to temporary workplace – ss 338 and 339 Income Tax (Earnings and Pensions) Act 2003 – Regulation 25 and paragraph 3 of part VIII of schedule 3 Social Security (Contributions) Regulations 2001 (SI 2001/1004) – series of assignments – whether overarching/umbrella … Continue reading Exchequer Solutions Limited v Revenue and Customs: FTTTx 13 Jun 2022

Moran v Revenue and Customs: FTTTx 30 Aug 2011

INCOME TAX – Appeal against Regulation 80 of the Income Tax (Pay As You Earn) Regulations 2003 determinations and Section 8 Social Contributions (Transfer of Functions) Act 1999 decisions and penalties – employer not accounting under PAYE for income tax and national insurance in respect of employees – had appellant failed to pay tax and … Continue reading Moran v Revenue and Customs: FTTTx 30 Aug 2011

Serpol Ltd v Revenue and Customs: FTTTx 14 Mar 2011

Appeal against determinations made under Regulation 80 of the Income Tax (Pay As You Earn) Regulations 2003 and a decision under Section 8 of the Social Security Contributions (Transfer of Functions etc) Act 1999 on basis that the taxpayers came within the agency legislation – appeal allowed in part as a result of exclusions Citations: … Continue reading Serpol Ltd v Revenue and Customs: FTTTx 14 Mar 2011

Spring Salmon and Seafood Ltd v Revenue and Customs: FTTTx 11 Sep 2014

FTTTx Income Tax; PAYE Determinations; National Insurance Contributions Decisions; bonus; effect of reference in accounts to fish stocks; whether paper transaction; whether contingent liability or accrual; Time Bar; deliberate conduct; whether liability excluded by agreement and/or undertaking; Taxpayer struck off Register of Companies and subsequently restored to the Register; effect of restoration; Income Tax (Pay … Continue reading Spring Salmon and Seafood Ltd v Revenue and Customs: FTTTx 11 Sep 2014

Kabir v Revenue and Customs: FTTTx 22 Jul 2014

FTTTx INCOME TAX – PAYE – Penalties and income tax – Whether sufficient evidence to displace decisions under s 8 Social Security Contributions (Transfer of Functions Etc.) Act 1999, Regulation 80 of the Income Tax (Pay As You Earn) Regulations 2003 determinations, Closure Notice and discovery assessments – No – Whether reasonable excuse for failure … Continue reading Kabir v Revenue and Customs: FTTTx 22 Jul 2014

Sheiling Properties Ltd v Revenue and Customs: CA 5 Oct 2021

Short but important issue about the scope of the statutory regime relating to accelerated payment notices introduced by the Finance Act 2014. The question, in brief, is whether the APN regime is prevented from applying to liabilities for pay as you . .