The claimant had been late in making class 2 national Insurance contributions over many years. The revenue appealed an order that it should have allowed the late paid contributions to count toward his pension entitlements. Held: The late payments may have been because of ignorance or lack of care or diligence, but that was not … Continue reading Revenue and Customs Commissioners v Thompson: ChD 28 Nov 2005
Statutory Sick Pay – disputed GP report – reference to Medical Services – HMRC Decision under s.8 Social Security Contributions (Transfer of Functions etc) Act 1999 – appeal dismissed Citations: [2022] UKFTT 358 (TC) Links: Bailii Jurisdiction: England and Wales Benefits Updated: 24 November 2022; Ref: scu.682698
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
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
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
CORPORATION TAX – computation of profits – deductions – payments by Appellant before 2001 to employee benefit trust and after 2002 to family benefit trust – whether wholly and exclusively expended for the purposes of the Appellant’s trade – yes – whether Appellant’s profits computed in accordance with generally accepted accountancy practice – yes – … Continue reading Sempra Metals Ltd v Revenue and Customs: SCIT 7 Jul 2008
FTTTx Industrial injuries disablement benefit – employed earner’s employment – contract of service or contract for services – s8 of the Social Security Contributions (Transfer of Functions, etc) Act 1999 -Appeal dismissed Citations: [2010] UKFTT 90 (TC) Links: Bailii Statutes: Social Security Contributions (Transfer of Functions, etc) Act 1999 8 Jurisdiction: England and Wales Benefits … Continue reading Convery v Revenue and Customs: FTTTx 23 Feb 2010
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
Appeal under section 8 of The Social Security Contributions (Transfer of Functions etc) Act 1999 – disputed married woman’s election – was election fraudulently made – no. Citations: [2012] UKFTT 476 (TC) Links: Bailii Jurisdiction: England and Wales Taxes – Other Updated: 03 August 2022; Ref: scu.466024
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
FTTTx 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 … Continue reading UBS Ag v Revenue and Customs: FTTTx 15 Sep 2010
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
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
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