The cases of Tower Radio Ltd and Total Property Support Services Ltd could have far-reaching consequences for anyone who has been involved in plans to utilise PAYE and NIC avoidance schemes. Appeals by the companies against tax charges were dismissed after the First-tier Tribunal judges decided that their scheme was so artificial that it fell within the broad Ramsay principle. Using an off-the-peg scheme, they had diverted bonuses into restricted shares in a new investment company, which they then liquidated, expecting the proceeds to be subject to capital gains tax. This failed, conceivably because it was deemed to be so flagrant.
