INCOME TAX – IT contractor employed by offshore company – loans made to taxpayer from employee benefits trust set up by employer – whether or not payments by employer to EBT were taxable earnings – accepted by appellant – whether or not HMRC entitled to raise discovery assessments under s29 TMA 1970 – held yes – whether or not HMRC entitled to exercise discretion under s 684(7A) ITEPA 2003 to disapply PAYE regulations – held yes – whether or not taxpayer alternatively subject to taxation under the transfer of assets abroad legislation – held yes, subject to the amount of the income of the person abroad – whether or not EU law principle of free movement of capital prevents application of TOAA legislation – held no because discrimination is justified by tax avoidance purpose of TOAA legislation
[2019] UKFTT 489 (TC), [2019] STI 1484, [2019] SFTD 1195
Bailii
England and Wales
Cited by:
Appeal from – Hoey v Revenue and Customs UTTC 12-Apr-2021
INCOME TAX� UK contractor with offshore employer providing services to UK end-users remunerated through EBT arrangements – whether FTT had jurisdiction to consider whether taxpayer entitled to PAYE credits under Regulations 185 and 188 of PAYE . .
These lists may be incomplete.
Updated: 20 June 2021; Ref: scu.641276