Nigel Doran partner in the corporate tax group at Macfarlanes considers the decision in Telent plc v HMRC on whether payments to a FURBS were 'earnings' for NIC purposes
In Town Investments Ltd v Department of the Environment [1978] AC 359 Lord Diplock described the word 'business' as 'an etymological chameleon; it suits its meaning to the context in which it is found'. If the recent Special Commissioners' decision in Telent plc v HMRC SpC 632 is correct it seems that the same might be said of the word 'earnings'. At least that word may mean one thing for income tax purposes and another for NIC purposes.
The facts
In the...
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Nigel Doran partner in the corporate tax group at Macfarlanes considers the decision in Telent plc v HMRC on whether payments to a FURBS were 'earnings' for NIC purposes
In Town Investments Ltd v Department of the Environment [1978] AC 359 Lord Diplock described the word 'business' as 'an etymological chameleon; it suits its meaning to the context in which it is found'. If the recent Special Commissioners' decision in Telent plc v HMRC SpC 632 is correct it seems that the same might be said of the word 'earnings'. At least that word may mean one thing for income tax purposes and another for NIC purposes.
The facts
In the...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
