FTTTx INCOME TAX – Employment Income – PAYE and NIC – tax avoidance scheme – bonus -whether bonus of restricted securities under Ch 2 Part 7 ITEPA 2003 or whether excluded as ‘money’ under s420(5)(b) ITEPA 2003 – bonus excluded from Part 7 as ‘money’ – GAAR proposal and enactment irrelevant to interpretation of provision – change in law which required re-engineering of scheme mid-way through did not affect conclusion that there was a scheme to pay bonus in money as opposed to securities -Regulation 80 determinations and s8 decisions upheld – appeals dismissed
Citations:
[2013] UKFTT 463 (TC)
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 19 May 2022; Ref: scu.515211
