Strategic Branding Ltd v Commissioners for HMRC WTLR(w) 2023-02

WTLR Issue: Web Only

STRATEGIC BRANDING LTD

V

COMMISSIONERS FOR HMRC

JUDGMENT JUDGE JEANETTE ZAMAN: Introduction [1] Strategic Branding Ltd (‘Strategic Branding’) has appealed against various assessments, decisions and determinations issued by HMRC which relate to contributions made by Strategic Branding to a remuneration trust, the WUT No. 1 Ltd Remuneration Trust (the ‘RT’), in circumstances where the amounts contributed (after payment of fees) were then …
This content is only available to members.

Counsel Details

Harriet Brown (Old Square Tax Chambers, 15 Old Square, Lincoln’s Inn, London WC2A 3UE, tell 020 7242 2744, email taxchambers@15oldsquare.co.uk), instructed by Griffin Law (60 Churchill Square, Kings Hill, West Malling ME19 4YU, tel 01732 525923, email justice@griffin.law) for the appellant.

Julian Ghosh KC (One Essex Court, Temple EC4Y 9AR, tel 020 7583 2000, email clerks@oeclaw.co.uk) and Barbara Belgrano, Quinlan Windle and Laura Ruxandu (Pump Court Tax Chambers, 16 Bedford Row, London WC1R 4EF, tel 020 7414 8080, email clerks@pumptax.com), instructed by the General Counsel and Solicitor to HM Revenue and Customs (HM Revenue and Customs Solicitor’s Office, 14 Westfield Avenue, Stratford, London E20 1HZ) for the respondents.

Legislation Referenced

  • Corporation Tax Act 2009
  • Income Tax (Earnings and Pensions) Act 2003
  • Income Tax (Pay As You Earn) Regs 2003
  • Social Security (Contributions) Regs 2001
  • Social Security (Transfer of Functions, etc.) Act 1999, s8
  • Social Security Contributions (Decisions and Appeals) Regs 1999
  • Social Security Contributions and Benefits Act 1992
  • Taxes Management Act 1970