Goldman Sachs International v HMRC (No 2)

Business tax: National insurance contributions: 'secondary contributor'

In Goldman Sachs International v HMRC (No 2) (TC00507 – 9 June) HMRC issued a ruling to a company (GSI) that the exercise of certain options to employees gave rise to a liability to national insurance contributions. GSI appealed contending that the staff were supplied by an associated company (GSL) and applied for a preliminary hearing to determine whether it could be treated as the employer of the employees who had exercised the options. The First-Tier Tribunal held a preliminary hearing reviewed the evidence in detail and determined the preliminary issue in favour of HMRC. Judge Williams found that GSL 'did not have a place of business in Great Britain at any time relevant to these appeals'. He held that GSL was a 'foreign employer' within Social Security (Categorisation of Earners)...