Rangers: Supreme Court rules on employees’ remuneration trust payments
In RFC 2012 Plc (formerly The Rangers Football Club Plc) v Advocate General for Scotland [2017] UKSC 45 (the Rangers case) the Supreme Court held that payments into an employees’ remuneration trust were earnings for income tax and NICs purposes.
The Rangers had implemented a tax avoidance scheme in which employers paid remuneration to their employees through an employees’ remuneration trust which made payments to sub-trusts for the benefit of named employees. The intended benefit of the scheme was the avoidance of liability to income tax (under PAYE) and NICs. The issue was whether the employee has to receive the remuneration for it to amount to taxable earnings.
The Supreme Court found that ‘a careful examination of the provisions of the primary legislation reveals no such requirement.’ The court pointed in...
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Rangers: Supreme Court rules on employees’ remuneration trust payments
In RFC 2012 Plc (formerly The Rangers Football Club Plc) v Advocate General for Scotland [2017] UKSC 45 (the Rangers case) the Supreme Court held that payments into an employees’ remuneration trust were earnings for income tax and NICs purposes.
The Rangers had implemented a tax avoidance scheme in which employers paid remuneration to their employees through an employees’ remuneration trust which made payments to sub-trusts for the benefit of named employees. The intended benefit of the scheme was the avoidance of liability to income tax (under PAYE) and NICs. The issue was whether the employee has to receive the remuneration for it to amount to taxable earnings.
The Supreme Court found that ‘a careful examination of the provisions of the primary legislation reveals no such requirement.’ The court pointed in...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
