Tom Wesel (Milestone International Tax Partners) believes that the Supreme Court should uphold the appeal by the liquidators of Rangers Football Club in what can be argued as an unjust and selective re-interpretation of the law.
Football clubs are ever more at the mercy of powerful players who can demand to be paid ‘gross’ of tax. Clubs have therefore increasingly resorted to EBTs to reduce their tax burden. In August 2010 HMRC declared its intention to attack these in Spotlight 5 stating its belief that when trust funds were allocated to named employees or their beneficiaries they became taxable earnings. Finance Act 2011 then introduced the disguised remuneration rules in ITEPA 2003 Part 7A. After this any earmarking of trust funds for particular employees became taxable with effect from 9 December 2010.
The question was what was to be done about EBTs established before this date. HMRC...
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Tom Wesel (Milestone International Tax Partners) believes that the Supreme Court should uphold the appeal by the liquidators of Rangers Football Club in what can be argued as an unjust and selective re-interpretation of the law.
Football clubs are ever more at the mercy of powerful players who can demand to be paid ‘gross’ of tax. Clubs have therefore increasingly resorted to EBTs to reduce their tax burden. In August 2010 HMRC declared its intention to attack these in Spotlight 5 stating its belief that when trust funds were allocated to named employees or their beneficiaries they became taxable earnings. Finance Act 2011 then introduced the disguised remuneration rules in ITEPA 2003 Part 7A. After this any earmarking of trust funds for particular employees became taxable with effect from 9 December 2010.
The question was what was to be done about EBTs established before this date. HMRC...
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