DOTAS scheme reference number properly allocated to umbrella company
In Greenwich Contracts Ltd v HMRC [2023] UKFTT 874 (TC) (12 October 2023) the FTT found that the burden of proof was on the taxpayer to show that HMRC had improperly allocated a scheme reference number (SRN) to it and that burden of proof had not been discharged.
The appellant (Greenwich) was an umbrella company which employed contractors that it supplied to clients on short term contracts. Greenwich paid the contractors the national minimum wage subject to deductions for income tax and NICs with the contractors receiving further payment (without such deductions) from a Maltese company.
HMRC allocated an SRN to these arrangements on the basis that it had reasonable grounds to suspect that they were notifiable arrangements under the disclosure of tax avoidance schemes (DOTAS) legislation in FA 2004 and that Greenwich was a promoter in...
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:
DOTAS scheme reference number properly allocated to umbrella company
In Greenwich Contracts Ltd v HMRC [2023] UKFTT 874 (TC) (12 October 2023) the FTT found that the burden of proof was on the taxpayer to show that HMRC had improperly allocated a scheme reference number (SRN) to it and that burden of proof had not been discharged.
The appellant (Greenwich) was an umbrella company which employed contractors that it supplied to clients on short term contracts. Greenwich paid the contractors the national minimum wage subject to deductions for income tax and NICs with the contractors receiving further payment (without such deductions) from a Maltese company.
HMRC allocated an SRN to these arrangements on the basis that it had reasonable grounds to suspect that they were notifiable arrangements under the disclosure of tax avoidance schemes (DOTAS) legislation in FA 2004 and that Greenwich was a promoter in...
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:
