UTTC Income Tax – Tax avoidance scheme – Dividend from new company instead of bonus: whether Ramsay jurispudence applies – Schedule E and meaning of emoluments from employment – Schedule F and meaning of dividend or distribution – Class 1 National Insurance Contribution.
Judges:
Mr Justice Roth and Judge Charles Hellier
Citations:
[2010] UKUT 251 (TCC), [2010] BTC 1626, [2010] STI 2274, [2010] STC 2343
Links:
Jurisdiction:
England and Wales
Citing:
At SCIT – PA Holdings Ltd v Revenue and Customs SCIT 29-Aug-2008
SCIT The Revenue issued separate decisions that certain sums paid to employees of Holdings in the three years to April 2003 were emoluments liable to income tax under PAYE and earnings on which Holdings is liable . .
Appeal from – PA Holdings Ltd and Another v Revenue and Customs FTTTx 7-May-2009
FTTTx Income tax – other – whether sums paid to individuals by a company as a dividend financed from a capital contribution to the company from employee benefits funds derived from the individuals’ employing . .
Cited by:
At UTTC – HM Revenue and Customs v PA Holdings Ltd CA 30-Nov-2011
The company made available to certain employees discretionary annual bonuses which were paid instead by way of shares and received dividends. It now appealed against findings that the payments were taxable subject to Schedule F rates and were liable . .
Lists of cited by and citing cases may be incomplete.
Income Tax
Updated: 01 September 2022; Ref: scu.428162