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Decision Number: |
TC 00063 |
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Appellant:
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PA Holdings Ltd and Kully Janjuah |
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Respondent:
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Her Majesty's Revenue & Customs |
Chairmen / Special
Commissioners: |
Adrian J SHIPWRIGHT
Dr David W WILLIAMS
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Date Of Decision:
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07/05/2009 |
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Main Category:
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NATIONAL INSURANCE CONTRIBUTIONS |
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Main Subcategory:
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Liability |
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Notes:
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Income tax – other – whether sums paid to individuals by a company as a dividend financed from a capital contribution to the company from employee benefits funds derived from the individuals’ employing company a distribution chargeable under Schedule F or emoluments from employment under Schedule E and subject to the PAYE Regulations – rules requiring exclusivity of Schedules applied
National Insurance contributions – liability – whether a decision that income taxable under Schedule F of the income tax as a distribution prevented the income also being subject to National Insurance contributions as earnings from employment.
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Decision(s) to Download:
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TC00063.doc 
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