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Decision Number: |
TC 02372 |
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Appellant:
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Murray Group Holdings and Others |
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Respondent:
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The Commissioners for Her Majesty's Revenue & Customs |
Chairmen / Special
Commissioners: |
Mr Kenneth MURE QC
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Date Of Decision:
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29/10/2012 |
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Main Category:
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INCOME TAX/CORPORATION TAX |
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Main Subcategory:
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Anti-avoidance |
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Notes:
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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
emoluments subject to PAYE and NIC; - (2) whether benefits (particularly
loans) derived by employees from the Remuneration Trust represent
emoluments subject to PAYE and NIC; - (3) “Ramsay” doctrine – whether
applicable – whether trust and loan arrangements artificial and fall to be
disregarded; - No - Appeal allowed. |
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Decision(s) to Download:
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TC02372.pdf 
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