Nigel Doran (Macfarlanes) revisits the case of HMRC v Tottenham Hotspur and recent case law concerning this frequently contentious distinction.
Those of us practising in the area of remuneration taxes have good reason to be thankful to the world of football for recent clarification of two contentious aspects of the charge to tax on earnings. Last summer in the Rangers FC case (RFC 2012 Plc v AG for Scotland [2017] UKSC 45) the Supreme Court confirmed that the flaw in employee benefit trusts was not that earmarking or allocating funds for an employee’s potential benefit might give rise to earnings but that the contribution to the trust itself constituted earnings. Now in the Spurs FC case (HMRC v Tottenham Hotspur Ltd [2017] UKUT 453 reported in Tax Journal 1 December 2017) the Upper Tribunal (UT) has shed some useful light on the...
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Nigel Doran (Macfarlanes) revisits the case of HMRC v Tottenham Hotspur and recent case law concerning this frequently contentious distinction.
Those of us practising in the area of remuneration taxes have good reason to be thankful to the world of football for recent clarification of two contentious aspects of the charge to tax on earnings. Last summer in the Rangers FC case (RFC 2012 Plc v AG for Scotland [2017] UKSC 45) the Supreme Court confirmed that the flaw in employee benefit trusts was not that earmarking or allocating funds for an employee’s potential benefit might give rise to earnings but that the contribution to the trust itself constituted earnings. Now in the Spurs FC case (HMRC v Tottenham Hotspur Ltd [2017] UKUT 453 reported in Tax Journal 1 December 2017) the Upper Tribunal (UT) has shed some useful light on the...
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:
