The Commissioners for HM Revenue and Customs v Murray Group Holdings Limited and Others: [2014] UKUT 0292(TCC)

Upper Tribunal Tax and Chancery decision of Lord Doherty on 8 July 2014.

Read the full decision in The Commissioners for HM Revenue and Customs v Murray Group Holdings Limited and Others: [2014] UKUT 0292(TCC).

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.

Published 1 December 2016