UTTC Income Tax and NIC – emoluments/earnings – tax avoidance scheme – remuneration trust – employees’ individual sub-trusts – ‘protectors’ – (1) whether payments into sub-trusts were emoluments/earnings subject to PAYE and NIC; -No (2) whether loans from sub-trusts were emoluments/earnings subject to PAYE and NIC; -No (3) ‘Ramsay’ principle – whether FTT erred in law; – No – Case remitted to FTT to determine certain matters, but otherwise appeal dismissed.
Citations:
[2014] UKUT 292 (TCC), [2014] STI 2409, [2015] STC 1, [2014] BTC 521
Links:
Statutes:
Income and Corporation Taxes Act 1988
Jurisdiction:
Scotland
Citing:
Appeal from – Murray Group Holdings and Others v Revenue and Customs FTTTx 29-Oct-2012
FTTTx Income Tax and NIC – Schedule E – emoluments/earnings – tax avoidance scheme – Remuneration Trust – employees’ individual sub-trusts – ‘protectors’ – (1) whether payments by employer into trust represent . .
Cited by:
Appeal From – The Advocate General for Scotland v A Decision of The Upper Tribunal, Re Assessments To Tax Made On Murray Group Holdings Ltd and Others SCS 4-Nov-2015
Second Division Inner House) The AG appealed from a finding that a tax avoidance was not a sham. TH AG brought a new argument, that the payment of the sums to the remuneration trust involved a redirection of the employee’s earnings and accordingly . .
AT UTTC – RFC 2012 Plc (Formerly The Rangers Football Club Plc) v Advocate General for Scotland SC 5-Jul-2017
The Court was asked whether an employee’s remuneration is taxable as his or her emoluments or earnings when it is paid to a third party in circumstances in which the employee had no prior entitlement to receive it himself or herself.
Held: The . .
Lists of cited by and citing cases may be incomplete.
Income Tax
Updated: 18 August 2022; Ref: scu.534525
