Tax advantage to remuneration arrangements: FA 2022 gives HMRC the power to publish information where (broadly) it suspects that the main benefit of arrangements is to obtain a tax advantage. In K (oao Payeworx Ltd) v HMRC [2024] EWHC 2842 (Admin) (8 November) the company provided workers to third parties under arrangements where the workers were paid a minimum wage and received the rest of their reward by means of a ‘dividend’ which was claimed to be tax free. The company argued that it was wrong for HMRC to suspect that there was a tax advantage in the arrangements. The main purpose of the arrangements it argued was to create an employment relationship so that the end users would not be required to apply PAYE under the off-payroll (IR35 rules). Its counsel said that the fact that HMRC did not like the arrangements and considered them to be...
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Tax advantage to remuneration arrangements: FA 2022 gives HMRC the power to publish information where (broadly) it suspects that the main benefit of arrangements is to obtain a tax advantage. In K (oao Payeworx Ltd) v HMRC [2024] EWHC 2842 (Admin) (8 November) the company provided workers to third parties under arrangements where the workers were paid a minimum wage and received the rest of their reward by means of a ‘dividend’ which was claimed to be tax free. The company argued that it was wrong for HMRC to suspect that there was a tax advantage in the arrangements. The main purpose of the arrangements it argued was to create an employment relationship so that the end users would not be required to apply PAYE under the off-payroll (IR35 rules). Its counsel said that the fact that HMRC did not like the arrangements and considered them to be...
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