INCOME TAX – whether the appellants are taxable on sums received under offshore partnership and trust arrangements as earnings under ITEPA – if so, whether the appellants are entitled to ‘credit’ for the resulting income tax which third parties were liable to deduct or account for under the Pay As You Earn System and are overcharged to tax – whether the tribunal can consider the appellants’ grounds of appeal relating to the ‘credit’ issue – whether the tribunal can consider the effect of decisions issued by HMRC under s 684(7A) ITEPA which HMRC argue prevent any ‘credit ‘arising – whether, in any event, the appellants are taxable on the sums under the provisions relating to the transfer of assets abroad – appeals dismissed
Citations:
[2020] UKFTT 407 (TC)
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 03 February 2022; Ref: scu.655336