The Grint case illustrates that HMRC may use the sale of occupational income provisions in even vanilla cases of tax planning, writes Oliver Marre (5 Stone Buildings).
The facts in R Grint v HMRC [2024] UKFTT 956 (TC) are as follows. In 2011 the actor Rupert Grint was in his early twenties. He had been working for a decade and his father managed his business affairs. On 1 August 2011 a UK-incorporated and UK tax resident company called Clay 10 Ltd (‘Clay 10’) was incorporated with Mr Grint as the sole shareholder and his father the company’s sole director. An agreement was concluded for Mr Grint to provide acting services to Clay 10. At that time Mr Grint had rights to be paid in respect of films in which he had already acted as well as the prospect of generating earnings in the future. These...
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The Grint case illustrates that HMRC may use the sale of occupational income provisions in even vanilla cases of tax planning, writes Oliver Marre (5 Stone Buildings).
The facts in R Grint v HMRC [2024] UKFTT 956 (TC) are as follows. In 2011 the actor Rupert Grint was in his early twenties. He had been working for a decade and his father managed his business affairs. On 1 August 2011 a UK-incorporated and UK tax resident company called Clay 10 Ltd (‘Clay 10’) was incorporated with Mr Grint as the sole shareholder and his father the company’s sole director. An agreement was concluded for Mr Grint to provide acting services to Clay 10. At that time Mr Grint had rights to be paid in respect of films in which he had already acted as well as the prospect of generating earnings in the future. These...
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