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Decision Number: |
TC 02853 |
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Appellant:
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LM Ferro Ltd |
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Respondent:
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The Commissioners for Her Majesty's Revenue & Customs |
Chairmen / Special
Commissioners: |
Swami RAGHAVAN
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Date Of Decision:
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29/08/2013 |
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Main Category:
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INCOME TAX/CORPORATION TAX |
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Main Subcategory:
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Employment income |
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Notes:
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INCOME TAX – Employment Income – PAYE & NIC – tax avoidance
scheme – bonus –whether bonus of restricted securities under Ch 2 Part 7
ITEPA 2003 or whether excluded as “money” under s420(5)(b) ITEPA 2003
– bonus excluded from Part 7 as “money” – GAAR proposal and enactment
irrelevant to interpretation of provision – change in law which required reengineering
of scheme mid-way through did not affect conclusion that there
was a scheme to pay bonus in money as opposed to securities -Regulation 80
determinations and s8 decisions upheld - appeals dismissed |
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Decision(s) to Download:
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TC02853.pdf 
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