Contractor loan scheme:P Sheth v HMRC[2023] UKFTT 368 (TC) (13 April 2023) is an appeal against assessments raised on a taxpayer who had used a contractor loan scheme. Unsurprisingly the FTT found that the principle established in the Rangers case that the arrangements involved a re-direction of earnings and therefore the amounts contribution to the trust were employment income applied here and so upheld the assessments. There are however two points worth noting.
The first is the taxpayer had repaid at least some of the loans – the evidence on this is not completely clear but it seems to have been accepted that there had been repayments. He argued that this meant that the loans were real loans and that it was wrong for HMRC to assess him as if the loans were taxable income. The FTT emphasised the point which may well not...
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Contractor loan scheme:P Sheth v HMRC[2023] UKFTT 368 (TC) (13 April 2023) is an appeal against assessments raised on a taxpayer who had used a contractor loan scheme. Unsurprisingly the FTT found that the principle established in the Rangers case that the arrangements involved a re-direction of earnings and therefore the amounts contribution to the trust were employment income applied here and so upheld the assessments. There are however two points worth noting.
The first is the taxpayer had repaid at least some of the loans – the evidence on this is not completely clear but it seems to have been accepted that there had been repayments. He argued that this meant that the loans were real loans and that it was wrong for HMRC to assess him as if the loans were taxable income. The FTT emphasised the point which may well not...
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