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 company a distribution chargeable under Schedule F or emoluments from employment under Schedule E and subject to the PAYE Regulations – rules requiring exclusivity of Schedules applied National Insurance contributions – liability – whether a decision that income taxable under Schedule F of the income tax as a distribution prevented the income also being subject to National Insurance contributions as earnings from employment.


[2009] UKFTT 95 (TC)




England and Wales


At SCITPA 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 . .

Cited by:

Appeal fromP A Holdings UTTC 7-Jul-2010
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 . .
At FTTTxHM 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: 03 August 2022; Ref: scu.373659