Philip Fisher warns employers who use aggressive dividend remuneration planning to review their arrangements.
HMRC received an early Christmas present last year thanks to the generosity of the Court of Appeal in the case of HMRC v PA Holdings Ltd [2011] EWCA Civ 1414. This was no unwanted pair of socks either. Potentially the decision could have unpleasant ramifications for the tax planning industry not to mention many companies for years to come. Coming hard on the heels of the disguised remuneration legislation it will potentially have a significant effect on corporate remuneration strategy in future.
The arguments
In brief the purposive interpretation of legislation by Lord Justice Moses and his two colleagues could bring the Exchequer a...
