Rory Mullan QC (Old Square Tax Chambers) examines the Upper Tribunal decision in S Hoey v HMRC which provides a degree of clarity on the tax consequences of contractor loan schemes.
In RFC 2012 (in liquidation) v Advocate General for Scotland [2017] UKSC 45 (‘Rangers’) the Supreme Court held that remuneration of an employee which was redirected to a trust on his behalf was taxable as his earnings. Furthermore it was made clear that such a redirection was subject to PAYE. This was a significant victory for HMRC reversing the effect of earlier losses before the Special Commissioners in Dextra Accessories Ltd v Macdonald [2002] STC (SCD) 413 and Sempra Metals Ltd v HMRC [2008] STC (SCD) 1062 and clarifying that loan arrangements which had been widely used over a number of years were generally ineffective to reduce liability to tax.
Rangers has not however been...
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Rory Mullan QC (Old Square Tax Chambers) examines the Upper Tribunal decision in S Hoey v HMRC which provides a degree of clarity on the tax consequences of contractor loan schemes.
In RFC 2012 (in liquidation) v Advocate General for Scotland [2017] UKSC 45 (‘Rangers’) the Supreme Court held that remuneration of an employee which was redirected to a trust on his behalf was taxable as his earnings. Furthermore it was made clear that such a redirection was subject to PAYE. This was a significant victory for HMRC reversing the effect of earlier losses before the Special Commissioners in Dextra Accessories Ltd v Macdonald [2002] STC (SCD) 413 and Sempra Metals Ltd v HMRC [2008] STC (SCD) 1062 and clarifying that loan arrangements which had been widely used over a number of years were generally ineffective to reduce liability to tax.
Rangers has not however been...
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:
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