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D T E Financial Services Ltd v Wilson (Inspector of Taxes): ChD 9 Nov 1999

A scheme involving the use of offshore discretionary trusts resulting in the payment of funds to the directors of the company from which the payments originated was not effective to exclude such payments from liability to tax. Overall the scheme had the characteristics of artificiality allowing all but one steps to be disregarded. Nevertheless the … Continue reading D T E Financial Services Ltd v Wilson (Inspector of Taxes): ChD 9 Nov 1999

Rogers v Revenue and Customs: FTTTx 11 Mar 2011

FTTTx Income tax – employment income – whether receipt of shares was an emolument from employment within section 19 Income and Corporation Taxes Act 1988 – whether an obligation to deduct PAYE under sections 203F or 203B Income and Corporation Taxes Act 1988 Judges: Brannan TJ Citations: [2011] UKFTT 167 (TC) Links: Bailii Jurisdiction: England … Continue reading Rogers v Revenue and Customs: FTTTx 11 Mar 2011

DTE Financial Services Ltd v Wilson (Inspector of Taxes): CA 24 May 2001

A scheme by which an employer paid bonuses to senior staff by purchasing contingent reversionary interests in an overseas trust, and then assigning them to the staff without admitting liability for income tax or national insurance contributions when the interests fell into possession. The scheme failed under anti-avoidance provisions under Ramsay principles. The cash payment … Continue reading DTE Financial Services Ltd v Wilson (Inspector of Taxes): CA 24 May 2001