Nigel Doran partner in the corporate tax group at Macfarlanes LLP considers the decision in Sempra Metals Ltd v HMRC on the taxation of payments to and from employee benefit trusts
Some years ago the employee benefit trust (EBT) was a relatively uncontroversial arrangement. It gathered in contributions from the employer company and invested them with a view to making distributions to deserving employees in the future. The contributions were generally deductible for the employer company when reflected in the accounts as their purpose was the business purpose of incentivising the company's workforce by dangling a carrot in front of it. The incentive effect was however muted by virtue of the carrot being discretionary. A particular employee might pull out all the stops to attract the trustee's attention (or at least that...
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Nigel Doran partner in the corporate tax group at Macfarlanes LLP considers the decision in Sempra Metals Ltd v HMRC on the taxation of payments to and from employee benefit trusts
Some years ago the employee benefit trust (EBT) was a relatively uncontroversial arrangement. It gathered in contributions from the employer company and invested them with a view to making distributions to deserving employees in the future. The contributions were generally deductible for the employer company when reflected in the accounts as their purpose was the business purpose of incentivising the company's workforce by dangling a carrot in front of it. The incentive effect was however muted by virtue of the carrot being discretionary. A particular employee might pull out all the stops to attract the trustee's attention (or at least that...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
