A scheme involving the use of offshore discretionary trusts resulting in the payment of funds to the directors of the company from which the payments originated was not effective to exclude such payments from liability to tax. Overall the scheme had the characteristics of artificiality allowing all but one steps to be disregarded. Nevertheless the payment had been made by, in effect, a trustee for the company as an intermediary, and the payment was taxable.
Citations:
Gazette 17-Nov-1999, Times 09-Nov-1999
Statutes:
Income and Corporation Taxes Act 1988 203B
Jurisdiction:
England and Wales
Income Tax
Updated: 06 September 2022; Ref: scu.79770