Continue reading "Trusts: Shedding light on remuneration trusts"
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Trusts: Shedding light on remuneration trusts
Mary Ashley reports on a rare taxpayer win Cases like Marlborough are helpful to reveal how HMRC will form its arguments when it wants a tribunal to look at the overall effect of an arrangement rather than the detail. Marlborough DP Ltd v The Commissioners for Her Majesty’s Revenue & Customs [2021] is a First-tier …
Cases Referenced
Cases in bold have further reading - click to view related articles.
- HMRC v PA Holdings Ltd [2011] EWCA Civ 1414
- Marlborough DP Ltd v The Commissioners for Her Majesty’s Revenue & Customs [2021] UKFTT 304 (TC); [2021] WTLR 1329 FTT
- RFC 2012 plc (in liquidation) (formerly Rangers Football Club plc) v Advocate General for Scotland [2017] UKSC 45
- Scotts Atlantic Management Ltd & anor v Commissioners for HMRC [2015] UKUT 66 (TCC)