David Whiscombe examines Boyle, a First-tier Tribunal decision on a contractor loan scheme of the kind currently being challenged by HMRC
Contractor loan schemes have been promoted in different versions for many years. The details have varied but all have involved individuals signing an employment contract with an offshore company which then provides the individual’s services to an ‘end-user’ for a commercial fee. The offshore company pays the individual a relatively small salary and delivers the remainder of the fee (minus the operator’s charges of course) in one of a number of supposedly tax-free ways typically involving a loan. In September 2013 HMRC announced its general intention to challenge such schemes and recently the First-tier Tribunal handed down its decision in Boyle [2013] UKFTT 723 (TC). HMRC’s description of the decision...
