Thomas Wallace (WTT Consulting) explains what advisers need to do to take advantage of the variety of tax treatments that are on offer.
Nearly five years on from the decision in RFC 2012 PLC v Advocate General for Scotland [2017] UKSC 45 it is hard to imagine that there are many tax advisors out there claiming that disguised remuneration schemes achieve the tax advantages that were claimed when they were first sold. As a reminder in general such schemes worked by the employer settling funds with a third party who then facilitated long-term loans with generous repayment terms. Such loans were claimed to escape taxation as they were not income in the hands of the recipient. HMRC having initially unsuccessfully argued at First-tier and Upper Tribunals that the loans themselves were taxable on receipt succeeded in reversing the views of the lower Courts when they changed...
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Thomas Wallace (WTT Consulting) explains what advisers need to do to take advantage of the variety of tax treatments that are on offer.
Nearly five years on from the decision in RFC 2012 PLC v Advocate General for Scotland [2017] UKSC 45 it is hard to imagine that there are many tax advisors out there claiming that disguised remuneration schemes achieve the tax advantages that were claimed when they were first sold. As a reminder in general such schemes worked by the employer settling funds with a third party who then facilitated long-term loans with generous repayment terms. Such loans were claimed to escape taxation as they were not income in the hands of the recipient. HMRC having initially unsuccessfully argued at First-tier and Upper Tribunals that the loans themselves were taxable on receipt succeeded in reversing the views of the lower Courts when they changed...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
