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Decision Number: |
TC 00779 |
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Appellant:
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Aberdeen Asset Management Plc |
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Respondent:
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The Commissioners for Her Majesty's Revenue & Customs |
Chairmen / Special
Commissioners: |
J Gordon REID QC
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Date Of Decision:
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29/10/2010 |
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Main Category:
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INCOME TAX/CORPORATION TAX |
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Main Subcategory:
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Other |
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Notes:
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Income Tax; emoluments; money’s worth; transfer of shares; readily convertible asset; Ramsay approach; tax avoidance scheme; Employee Benefit Trust; Discounted Options Scheme for employees in financial services industry; establishment of employee benefit trust; offshore companies established; money box company; family trust established; grant of option by offshore company in favour of family trust; transfer of shares to employee; value of shares; whether existence of family trust diluted value of shares transferred; Income & Corporation Taxes Act 1988 sections 1 19, 131, 202A&B, 203F The Income Tax (Employments) Regulations 1993 Regulation 2; (Pay As You Earn) Regulations 2003 Regulation 80, National Insurance; Social Security Contributions (Transfer of Functions) Act 1999 section 8; |
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Decision(s) to Download:
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TC00779.doc 
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