United Kingdom Upper Tribunal (Tax and Chancery Chamber)

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You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> Revenue And Customs v Murray Group Holdings Ltd & Ors [2014] UKUT 292 (TCC) (08 July 2014)
URL: http://www.bailii.org/uk/cases/UKUT/TCC/2014/292.html
Cite as: [2014] UKUT 292 (TCC), [2014] STI 2409, [2015] STC 1, [2014] BTC 521

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Revenue And Customs v Murray Group Holdings Ltd & Ors [2014] UKUT 292 (TCC) (08 July 2014)

Income Tax and NIC – emoluments/earnings – tax avoidance scheme - remuneration trust – employees’ individual sub-trusts – “protectors” - (1) whether payments into sub-trusts were emoluments/earnings subject to PAYE and NIC; -No (2) whether loans from sub-trusts were emoluments/earnings subject to PAYE and NIC; -No (3) “Ramsay” principle - whether FTT erred in law; - No - Case remitted to FTT to determine certain matters, but otherwise appeal dismissed.

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