LM Ferro Ltd v Revenue and Customs: FTTTx 29 Aug 2013

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


[2013] UKFTT 463 (TC)




England and Wales

Income Tax

Updated: 19 May 2022; Ref: scu.515211