A scheme by which an employer paid bonuses to senior staff by purchasing contingent reversionary interests in an overseas trust, and then assigning them to the staff without admitting liability for income tax or national insurance contributions when the interests fell into possession. The scheme failed under anti-avoidance provisions under Ramsay principles. The cash payment received was a payment of assessable income under section 203(1) and consideration of later sections was unnecessary.
Citations:
Times 03-May-2001, Gazette 24-May-2001, [2001] EWCA Civ 455
Links:
Statutes:
Income and Corporation Taxes Act 1988 203(1) 203B 203F
Jurisdiction:
England and Wales
Citing:
Cited – W T Ramsay Ltd v Inland Revenue Commissioners HL 12-Mar-1981
The taxpayers used schemes to create allowable losses, and now appealed assessment to tax. The schemes involved a series of transactions none of which were a sham, but which had the effect of cancelling each other out.
Held: If the true nature . .
Lists of cited by and citing cases may be incomplete.
Taxes Management, Income Tax
Updated: 19 May 2022; Ref: scu.80145