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, 203, 203A, 203F, The Income Tax (Employments) Regulations 1993 Regulation 2- appeal dismissed

Citations:

[2012] UKUT 43 (TCC)

Links:

Bailii

Statutes:

Income Tax (Employments) Regulations 1993, Income and Corporation Taxes Act 1988

Jurisdiction:

England and Wales

Citing:

At FTTTxAberdeen 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 . .

Cited by:

At UTTCAberdeen 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.452883