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Big Rangers Administration/Liquidation Thread - All chat here!


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Did you not learn from the last time, a think the term is innocent until proving guilty.

Yes, indeed, "Innocent until proven guilty", i'm all for that.

Now, Click the red link below and read in full that which is contained. smile.gif

CLICK HERE.

ANONYMISED FORM OF THE DECISION

[2012] UKFTT 692 (TC)

TC02372

Appeal number: SC/3113-3117/2009

Income Tax and NIC – Schedule E – emoluments/earnings – tax avoidance

scheme - Remuneration Trust – employees' individual sub-trusts –

"protectors" - (1) whether payments by employer into trust represent

emoluments subject to PAYE and NIC; - (2) whether benefits (particularly

loans) derived by employees from the Remuneration Trust represent

emoluments subject to PAYE and NIC; - (3) "Ramsay" doctrine – whether

applicable – whether trust and loan arrangements artificial and fall to be

disregarded; - No - Appeal allowed.

FIRST-TIER TRIBUNAL

TAX CHAMBER

MURRAY GROUP HOLDINGS and OTHERS Appellants

- and -

THE COMMISSIONERS FOR HER MAJESTY'S

REVENUE & CUSTOMS Respondents

TRIBUNAL JUDGE:

Mr Kenneth Mure, QC

Dr Heidi Poon, CA, CTA, PhD

S A Rae, LLB., WS

Sitting in private at George House, 126 George Street, Edinburgh on 25 October –

5 November 2010, 18-21 and 26-28 April, 3-6 May and 7-10 and 16 November 2011, and

16-18 January 2012

Andrew Thornhill QC, Mark Studer, Jonathan Bremner and Thomas Chacko,

Barristers, for the Appellants

Roderick N Thomson, QC., instructed by the Office of the Advocate General, for the

Respondents

© CROWN COPYRIGHT 2012

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